2012 GRANT MANAGEMENT HANDBOOK

Transcription

1 OREGON DEPARTMENT OF JUSTICE VICTIMS OF CRIME ACT (VOCA) 2012 GRANT MANAGEMENT HANDBOOK Attorney General Ellen F. Rosenblum Oregon Department of Justice Crime Victims Services Division 1162 Court Street NE Salem, OR (503)

2 The Victims of Crime Act (VOCA) Grant Management Handbook discusses general program requirements and restrictions relating to the administration of all federal VOCA grant awards funded through the Oregon Department of Justice (DOJ), Crime Victims Services Division (CVSD). It is expected that this Handbook will provide a ready resource for those agencies in the process of applying for a VOCA Grant, as well as, providing grant recipients with a resource throughout the grant period. The VOCA Grant Management Handbook is available in the following formats: o Downloadable in PDF format on the Department of Justice (DOJ) Crime Victims Services (CVSD) website at: o Electronic Mail ( ) The minimum system requirements to open electronic documents are: o Microsoft Windows 2000, P, or Vista; o Microsoft Excel 97 or later; and o Adobe Reader 6 or later (to download a free version of Adobe Reader, go to: In order to align with the reporting compatibility issues within the CVSD grant unit, we recommend downloading Adobe Reader ). DOJ Grant Assistants Krista Anderson or Joy Richardson: Phone: (503) Fax: (503) [email protected] or [email protected] For additional information, please contact: Jeanette Ewald (503) [email protected] Mackenzie Gray (503) [email protected] Mailing Address: Oregon Department of Justice, Crime Victims Services Division 1162 Court Street NE Salem, Oregon Fax:(503) Cathy Oliverio Relang (503) [email protected] For information on Oregon s Crime Victim Compensation Program (CVCP), please contact: Joe McCarty, Crime Victim Compensation Manager Phone: (503) [email protected] Toll-free within the State of Oregon: (800) Revised July 2012: This revision supersedes all previously issued Handbooks.

3 TABLE OF CONTENTS SECTION 1: INTRODUCTION TO VOCA GUIDELINES I. What is VOCA?... Page 1 II. Summary of VOCA Fund Activity... Pages 1-2 III. What is the Purpose of VOCA Grants?... Page 2 IV. Who is Eligible?... Pages 2-3 A. Agencies eligible to receive VOCA funds... Pages 2-3 B. Agencies not eligible to receive VOCA funds... Page 3 V. What are the Requirements of Eligibility?... Pages 3-4 VI. Allowable Services, Activities and Costs... Pages 4-10 A. Direct Services... Pages 4-7 B. Other Allowable Costs and Services... Pages 7-10 VII. Unallowable Services, Activities and Costs... Pages A. Lobbying and Administrative Advocacy... Page 10 B. Perpetrator Rehabilitation and Counseling... Page 10 C. Needs Assessments, Surveys, Evaluations, Studies and Reseach... Page 11 D. Prosecution Activities... Page 11 E. Fundraising Activities... Page 11 F. Indirect Organizational Costs... Page 11 G. Reimbursement of Crime-Related Expenses (i.e., property loss)... Page 11 H. Most Medical Costs... Pages 12 I. Victim Relocation Expenses... Page 12 J. Administrative Staff Expenses... Page 12 K. Development of Protocols, Interagency Agreements & Other Working AgreementsPage 12 L. Costs of Sending Individual Crime Victims to Conferences... Page 12 M. Activities Exclusively Related to Crime Prevention and Public Education... Page 12 N. Purchase of Vehicles or Buildings... Page 12 O. Coordination of Community Efforts... Page 13 P. Non-Emergency Legal Services... Page 13 Q. Audits for Public Agencies or Non-Profit Organizations (under $500, in federal funds)... Page 13 R. Costs Incurred Outside the Project Period... Page 13 SECTION 2: VOCA GRANT APPLICATION PROCESS I. Target Populations to be Served... Page 14 II. Funding Categories... Pages A. Non-Competitive Grants (previously referred to as Basic)... Pages B. Competitive Grants (previously referred to as Project)... Page 16 SECTION 3: GRANTEE ELIGIBILITY REQUIREMENTS I. Record of Effective Services... Page 17 II. Conditional Awards... Page 17 III. Match Requirements... Pages IV. Volunteers... Page 19 V. Coordinated Public and Private Efforts... Pages VI. Crime Victims Compensation Program Assistance... Page 20

4 VII. No Charge to Victims... Page 20 VIII. Victims of Federal Crimes... Page 20 I. Confidentiality of Personal Information... Pages Confidentiality of Research Information... Page 21 I. Compliance with the Federal Funding Accountability and Transparency Act (FFATA) of Pages II. Certified Assurances & Other Certifications... Pages A. Non-supplantation... Page 23 B. Civil Rights Compliance... Pages C. Comply with Certifications Regarding Lobbying; Debarment, Suspension and Other Responsibility Matters; and Drug-Free Workplace Requirements... Pages D. Equal Treatment for Faith Based Organizations... Pages E. Compliance with State Criteria and Victims Rights... Pages III. Demonstrates Access to Effective Services... Page 27 IV. Maintains Good Fiscal Management... Page 27 V. Maintains Adequate Insurance Coverages......Pages A. Nonprofit Agencies... Pages B. Intergovernmental Agencies... Page 28 VI. Complies with Financial, Data and Outcome Reporting... Page 28 VII.Services Provided are Culturally Competent and Accessible... Page 28 VII I. Complies with Training Requirements... Page 28 SECTION 4: VOCA MANAGEMENT AND OPERATIONS GUIDELINES I. Introduction... Page 29 II. Guidelines for Employee Management... Pages A. Staff Issues... Page 29 B. Volunteers... Pages C. Criminal History Verification (Background Checks)... Pages D. Other... Page 32 III. Guidelines for Contractual Services... Pages IV. Guidelines for a Memorandum of Understanding... Page 34 V. Guidelines for Training and Travel... Pages A. Travel/Mileage for Direct Services... Page 34 B. Training Related Travel... Page 344 C. Training Outside of Oregon... Page 35 D. Unallowable Costs Related to Training... Page 35 SECTION 5: REPORTING REQUIREMENTS I. Overview... Page 36 II. Reporting Requirements... Pages A. Quarterly Financial Reports (QFRs)... Pages B. Semi-Annual Performance Reports... Pages III. Non Compliance With Reporting... Page 42 IV. Other Required Communication... Pages A. Request for Amendements... Pages B. Achievement of Operational Status/Grant Commencement... Page 44 C. Termination of a Grant... Page 44

5 SECTION 6: FINANCIAL REQUIREMENTS I. Office of Justice Programs (OJP) Financial Guide... Page 45 II. OMB Circular/Code of Federal Regulations Pertaining to Fiscal Requirement... Pages III. Award Requirements... Pages A. Standards for Financial Management Systems... Pages B. Program Income... Page 49 C. Property and Equipment... Page 49 D. Procurement Standards... Pages SECTION 7: GRANTEE MONITORING I. Overview... Page 52 II. Site Visits... Page 52 III. Failure to Comply with the Terms and Conditions of a VOCA Grant... Page 53 APPENDICES APPENDI A... Semi Annual Statistical Report: Instructions and Service Definitions APPENDI B... Property and Equipment Requirements (from OJP Financial Guide) APPENDI C...Quick Reference Chart: Allowable and Unallowable Activities APPENDI D... Minimally Recommended Elements of an Independent Contractor Agreement APPENDI E... Memorandum of Understanding Sample Format and Content APPENDI F... VOCA Phone Review and Site Visit Monitoring Form APPENDI G... VOCA Grant Recipient Resource Page APPENDI H... VOCA Glossary of Terms APPENDI I..Subcontractor Insurance Requirements

6 SECTION 1 INTRODUCTION TO VOCA GUIDELINES I. WHAT IS VOCA? The Victims of Crime Act was passed by Congress and signed into law by President Reagan on October 12, The Act serves as the central source of federal financial support for direct services to victims of crime. VOCA is administered at the federal level through the United States Department of Justice, Office for Victims of Crime, which annually awards a grant to each state, the District of Columbia and the United States Territories. Those agencies, in turn, sub-grant to organizations that provide direct service to victims of crime. The money for these grants comes from the Crime Victims Fund, a special fund into which fines, penalty assessments, bond forfeitures collects from convicted federal offenders and certain other collections are deposited; taxpayers do not fund VOCA grants. Each state has a designated VOCA assistance agency to administer VOCA grants. While minimal federal requirements must be met, each state is given great discretion in awarding specific grants. The Oregon Department of Justice (DOJ) is the designated agency for the administration of VOCA funds in the State of Oregon. The Crime Victims Services Division (CVSD) of the Oregon Department of Justice has specific program responsibility for VOCA. The VOCA Advisory Committee serves as a review body and sounding board to DOJ and CVSD. The primary purpose of the VOCA victim assistance grant program is to extend and enhance services to victims of crime II. SUMMARY OF VOCA FUND ACTIVITY Each year, state VOCA assistance grants support direct services to approximately 4 million victims of all types of crimes (domestic violence, sexual assault, child abuse, drunk driving, elder abuse, robberies, and survivors of homicide victims, etc) by 4,400 local and state victim service agencies. VOCA also supports victim assistance for those involved in the federal criminal justice system, including survivors of terrorist acts. 1 The 2009 the VOCA allocation to the state of Oregon increased by approximately 17% above the 2008 state allocation. Due to the increase, CVSD was able to conduct a VOCA competitive application process and awarded 15 two-year grants totalling $1,055,681. In 2009, CVSD also received one-time funding through the American Recovery and Reinvestment Act of 2009 (ARRA) under the VOCA Victim Assistance Formula Grant Program. With these funds, 9 grants were awarded for a total of $713,450. What looks to be good news is on the horizon for VOCA. Since 2000, Congress has capped the annual obligations from the VOCA Fund to ensure stable funding in future years which has resulted in cuts to victim services. The Crime Victims Fund Preservation Act of 2009 (S.1340 and H.R. 3402) are bipartisan companion bills establishing a minimum funding level for VOCA programs and increases the cap by 23% each year for fiscal years through The minimum 1 Source: Fact Sheet 1

7 VOCA cap in the bills will ensure a reasonable growth in victim programs without jeopardizing the long-term sustainability of the Crime Victims Fund. The Consolidated Appropriations Act of 2010 includes a $705 million cap on obligations from the Crime Victims Fund, an increase of $70 million over the FY 2009 cap. Congress has enacted the FY 2012 Commerce, Justice and Science (CJS) appropriations which maintains the VOCA cap at $705 million. However, it requires the Office of Justice programs to support its management and administrative expenses with program funding. This new requirement resulted in an 11.5% decrease in Oregon s FY 2012 VOCA victim assistance grant. If you would like to read more about the VOCA Crime Victims fund visit the National Association of VOCA Assistance Administrators (NAVAA) website at: III. WHAT IS THE PURPOSE OF VOCA GRANTS? The primary purpose of the VOCA victim assistance grant program is to extend and enhance services to victims of crime. For the purposes of this program, a crime victim is a person who has suffered physical, sexual, financial or emotional harm as a result of the commission of a crime. VOCA grants are to support the direct provision of services to victims of crime throughout the United States. Research has shown that if victims receive early intervention, the need for long-term treatment dramatically decreases. IV. WHO IS ELIGIBLE? VOCA specifies that an organization must provide services to crime victims and be operated by a public agency, nonprofit organization, Native American tribe/organization, or a combination of such agencies or organizations in order to be eligible to receive VOCA funding. Eligible organizations include victim service organizations whose sole mission is to provide services to crime victims. In addition to victim service organizations, there are many other public and nonprofit organizations that have components which offer services to crime victims. These organizations are eligible to receive VOCA funds, if the funds are used to expand or enhance the delivery of crime victims services. A more detailed explanation appears on the following page. The specific eligibility criteria in any given funding year for the State of Oregon are determined by the VOCA Advisory Committee. A. Agencies eligible to receive VOCA funds: Nonprofit organizations providing direct services to crime victims. A nonprofit organization must be duly incorporated and registered under Oregon statutes, unless it is a tribal governing body or a local chapter of national tax-exempt victim service organizations (i.e., Mothers Against Drunk Driving, Parents of Murdered Children); Public (government) agencies, such as criminal justice agencies, including law enforcement, prosecutor offices, courts, corrections departments, probation and paroling authorities for victim services that exceed the boundaries of their mandate. For example, a police department may use VOCA funds to provide crime victim services that exceed a law enforcement official s normal duties, such as a victim crisis response unit. Regular law enforcement duties, such as crime scene intervention, questioning of victims and witnesses, investigations of the crime, and follow-up activities may not be paid with VOCA funds; 2

8 Native American tribes/organizations providing services to crime victims; Religiously-affiliated organizations, provided that services are offered to all crime victims without regard to religious affiliation and receipt of services is not contingent upon participation in a religious activity or event; Hospital and emergency medical facilities offering crisis counseling, support groups, and/or other types of victim services; and Others. State and local public agencies, such as mental health service organizations, state/local public child and adult protective services, state grantees, legal services agencies and programs with a demonstrated history of advocacy on behalf of domestic violence victims, and public housing authorities that have components specifically trained to serve crime victims. B. Agencies NOT eligible to receive VOCA funds: Federal agencies. This includes U.S. Attorneys Offices and local FBI Field Offices; as in this instance, receiving VOCA funds would constitute an augmentation of the federal budget with money intended for state agencies. However, private nonprofit organizations that operate on federal land may be eligible recipients of VOCA grant funds; and In-patient treatment facilities, for example, those designed to provide treatment to individuals with drug, alcohol, and/or mental health-related conditions. V. WHAT ARE THE REQUIREMENTS OF ELIGIBILITY? VOCA establishes criteria that must be met by all organizations receiving VOCA funds. An agency must meet all of the following criteria to receive VOCA funds (an expanded version of the criteria below is available in Section 3: pages 17-26). Federal Requirements: Demonstrate a record of providing effective direct services to crime victims; Programs that have not yet demonstrated a record of providing services may be eligible to receive VOCA funding, if they can demonstrate that 25% of their financial support comes from non-federal sources; Meet program match requirements. Match must be derived from non-federal funds and must be used for VOCA eligible activities. Match is 25% of the federal amount received and can be in-kind or cash; Use volunteers to provide or support direct victim services; Promote coordinated public and private efforts to aid crime victims within the community; 3

9 Assist victims in seeking crime victim compensation benefits; Provide services to crime victims, at no charge, through the VOCA-funded project; Maintain civil rights information; Provide services to victims of federal crime on the same basis as victims of state crime; Maintain the confidentiality of client-counselor information, as required by state and federal law; Maintain confidentiality of research information; Compliance with the Federal Funding Accountability and Transparency Act (FFATA) of 2006, proof of Data Universal Numbering System (DUNS) number, and proof of current registration in the Central Contractor Registration (CCR) database (see page 22 for details on how to obtain a DUNS number and CCR or SAM registration); and Meet the terms of the Certified Assurances and other federal rules regulating grants, including non-supplantation, civil rights compliance, and the Certifications regarding lobbying, debarment, suspension and other responsibility matters, and drug-free workplace requirements. CVSD Requirements: Demonstrates access to effective services; Maintains good fiscal management; Non-profit grantees and nonprofit subcontractors of intergovernmental grantees must obtain and maintain adeqinteruate insurance coverages. Complies with financial, data and outcome reporting; Services provided are culturally competent and accessible; and Grantees are required to comply with VOCA program guidelines as written in this Handbook including any additional eligibility or service criteria defined at any point during the award periods established by CVSD. Complies with training requirements. VI. ALLOWABLE SERVICES, ACTIVITIES AND COSTS A. Direct Services The costs below for direct services are eligible for support with VOCA grant funds within an organization: 4

10 1. Immediate Health and Safety Services which respond to immediate emotional and physical needs (excluding medical care) of crime victims, such as: crisis intervention; accompaniment to hospitals for medical examinations; crisis hotline counseling; emergency food, clothing, transportation, and shelter (including emergency, short-term nursing home shelter for elder abuse victims for whom no other safe, short-term residence is available); and other emergency services that are intended to restore the victim s sense of security. This includes services which offer an immediate measure of safety to crime victims, such as boarding up broken windows and replacing or repairing locks. Also allowable is emergency legal assistance, such as filing restraining orders and obtaining emergency custody/visitation rights when such actions are directly connected to family violence cases and are taken to ensure the health and safety of the victim. Regarding emergency funds used to meet the critical emergency financial needs of crime victims, written policies must be established that specify the types of expenses to be covered by an emergency fund, the method of monitoring and accounting for such funds, and any work or repayment requirements. Emergency payments must be itemized as to the specific nature of each emergency and the expenses paid. The victim s identity is not required. This information is to be kept in the appropriate VOCA file. It is advised that careful attention be given to the use of VOCA funds for emergency expenses which might also be covered under the state Crime Victims Compensation Program. Payment under a VOCA emergency fund would be considered a collateral resource and may be deducted from a victim s compensation benefits. 2. Mental Health Assistance Mental health assistance includes those services that assist primary and secondary victims in understanding the dynamics of victimization and in stabilizing their lives after victimization, including counseling, group treatment and therapy. Therapy refers to intensive, professional psychological/ psychiatric treatment for individuals, couples, and family members related to counseling to provide emotional support in crises arising from the occurrence of crime. This includes the evaluation of mental health needs, as well as the actual delivery of psychotherapy. Intensive, professional, psychological/psychiatric treatment and/or counseling are differentiated from peer support by an emphasis on a therapeutic process tailored by an individual treatment plan. VOCA funds are not intended for long-term intensive therapy in individual settings. VOCA funds may be used for up to six months of crisis intervention in group therapy. This may include family therapy for victims of child abuse. 3. Assistance with Participation in Criminal Justice Proceedings This includes advocacy on behalf of crime victims to assist them in asserting their rights in criminal justice proceedings, including: accompaniment to criminal justice offices and court; transportation to court; child care to enable a victim to attend court; notification to victims regarding trial dates; case disposition information and parole 5

11 consideration proceedings; restitution advocacy; and assistance with victim impact statements. VOCA funds are to be used to expand or enhance the delivery of crime victims services, that is, services that are provided to victims when the motivation for participation in criminal justice proceedings comes from victims exercising their victims rights. 4. Costs Necessary and Essential to Providing Direct Services This includes prorated costs of victim service agency rent, water, sewer, heat and electricity, telephone service, transportation costs for victims to receive services, and local travel expenses for service providers. Emergency transportation costs that enable a victim to participate in the criminal justice system are also allowable. 5. Forensic Examinations For sexual assault victims, forensic medical exams are allowable only to the extent that other funding sources (i.e., Oregon s Sexual Assault Victims Emergency Medical Response Fund, private insurance, or public benefits) are unavailable or insufficient to cover the cost of the exam. 6. Special Services Examples include assisting victims with managing practical problems created by the victimization; acting on behalf of the victim with other service providers, creditors, or employers; assisting the victim to recover property that is retained as evidence; assisting in filing for compensation benefits; and helping the victim to apply for public assistance. 7. Personnel Costs These include costs that are directly related to providing direct services, such as staff salaries and benefits, including malpractice insurance; the cost of advertising to recruit VOCA funded personnel; and the cost of training for paid and volunteer staff. VOCA funds may be used as payment for state and federal taxes, including all employer paid taxes. VOCA funds may be used for immediately expendable benefits such as state and federal taxes and medical coverage. VOCA funds may be used to contribute to 401K plans, pension plans or the like. 8. Restorative Justice This includes opportunities for crime victims to meet with perpetrators, if such meetings are requested or voluntarily agreed to by the victim and would result in a possible beneficial or therapeutic value to crime victims. These services will be closely reviewed. At a minimum, the following will be considered: The safety and security of the victim; The benefit or therapeutic value to the victim; The procedures for ensuring that participation of the victim and offender are voluntary and that all parties understand the nature of the meeting; The provision of appropriate support and accompaniment for the victim; 6

12 Appropriate debriefing opportunities for the victim after the meeting or panel; The credentials of the facilitators; and The opportunity for a crime victim to withdraw from the process at any time. 9. Unfunded State Mandate VOCA funds may be used to implement state laws when it has been established that the mandate does benefit crime victims and no other funds are available to implement the mandated activity. The mandated activity must be a VOCA allowable service. Please note that Oregon s VOCA Administrator must determine that VOCA funds are not supplanting state or local funds that would otherwise be available for this purpose. B. Other Allowable Costs and Services The services, activities and costs listed below, though not direct crime victim services, are often necessary to ensure that quality direct services are provided. Before these costs can be supported with VOCA funds, it must be established that direct services to crime victims cannot be provided without these expenditures. Only limited amounts of VOCA funds may be used for these purposes. The following list provides examples of such items: 1. Skills Training for Staff VOCA funds designated for training are to be used exclusively for developing the skills of direct service providers, including paid staff and volunteers, so that they are better able to offer quality services to crime victims. An example of skills development is training focused on how to respond to a victim in crisis. VOCA funds can be used for training both VOCA funded and non-voca-funded service providers who work within a VOCA recipient organization. VOCA funds cannot be used for management and administrative training for executive directors, board members, and other individuals who do not provide direct services. 2. Training Materials VOCA funds can be used to purchase materials such as books, training manuals and videos for direct service providers within the VOCA funded organization, and can support the costs of a trainer for in-service staff development. Staff from other organizations can attend in-service training activities that are held for the grant recipient s staff. 3. Training Related Travel VOCA funds can support costs such as travel, meals, lodging and registration fees to attend training within the state or a similar geographic area. Please refer to pages for more information. 4. Membership Dues Agency (not individual or personal) membership dues in organizations which offer needed, timely and relevant information on victim services and issues (i.e., National Organization for Victims Assistance, National Center for Victims of Crime, Crime Victims Assistance Network) are allowed. Memberships in no more than three (3) 7

13 eligible organizations may be paid for with VOCA funds. Membership or fees for organizations that are not exclusively related to victim assistance or that are required for professional licensing may not be charged to VOCA. 5. Furniture and Equipment VOCA funds may be used to purchase furniture and equipment that provides or enhances direct services to crime victims. VOCA funds cannot support the entire cost of an item unless that item is used exclusively for victim related activities. However, VOCA funds can support a prorated share of such an item. In addition, grantees cannot use VOCA funds to purchase equipment for another organization or individual to perform a victim related service. Examples of allowable costs may include: pagers, computers and typewriters; videotape cameras and recording equipment for interviewing children; and two-way mirrors and equipment and furniture for shelters, workspaces, victim waiting rooms and children s play areas. The costs of furniture or equipment that make victims services more accessible to persons with disabilities, such as a TTY/TTD machine for the deaf, are allowable. 6. Leasing Vehicles VOCA funds may be used to lease vehicles if the grantee agency can demonstrate that such expenditure is essential to delivering services to crime victims. Oregon s VOCA Administrator must give prior approval for all such leases. The purchase of vehicles with VOCA funds is strictly prohibited. 7. Advanced Technologies At times, computers or other technologies may increase a grantee s ability to reach and serve crime victims. In making such expenditures, VOCA grantees must describe: how the technology will enhance services to crime victims; how it will be integrated into and/or enhance the grantee s current system; the cost of installation; the cost of training staff to use the technology; the ongoing operational costs, such as maintenance agreements or supplies; and how these additional costs will be supported. Property insurance is also an allowable expense as long as VOCA funds support a prorated share of the insurance payments. 8. Contracts for Professional Services VOCA funds generally should not be used to support contract services. At times, however, it may be necessary for VOCA grantees to use a portion of the VOCA grant to contract for specialized services (i.e., assistance in filing restraining orders, services of a play therapist, etc). Please refer to pages for more information. 9. Operating Costs Operating costs are not considered indirect costs. Examples of allowable operating costs include: supplies; equipment use fees (when supported by usage logs); printing, photocopying and postage; brochures that describe available services; books and other victim-related materials. These costs should be prorated for the portion of the agency budget funded by VOCA. VOCA funds may support administrative time to 8

14 complete VOCA required time and attendance sheets, programmatic documentation, reports and statistics, and crime victims records. 10. Supervision of Direct Service Providers VOCA funds may support the supervision of direct service providers when it is determined that such supervision is necessary and essential to providing direct services to crime victims. For example, using VOCA funds to support a coordinator of volunteers or interns is a cost effective way of serving more crime victims. 11. Repair and/or Replacement of Essential Items VOCA funds may be used for repair or replacement of items that contribute to maintaining a healthy and/or safe environment for crime victims, such as a furnace in a shelter. The grantee must provide assurance of all of the following: That the building is owned by the grantee organization and not rented or leased; All other sources of funding have been exhausted; There is no available option for providing the service in another location; That the cost of the repair or replacement is reasonable considering the value of the building; and The cost of the repair of replacement is prorated among all sources of income. 12. Public Presentations to Increase Access to Services for Crime Victims VOCA funds may be used to increase access to services for crime victims and may support presentations that are made in schools, community centers, or other public forums. These presentations must be designed to identify crime victims, inform participants of agency services and available options and/or refer them to needed services. Presentations to the community designed to recruit and train volunteers for the victim service program are allowable. Presentations that are designed specifically for prevention or for educational purposes are not allowable under VOCA. The costs related to such programs, including presentation materials, brochures and newspaper notices, can be supported by VOCA funds. However, these presentations should be limited in number, as a majority of VOCA funds should not be utilized for this purpose. 13. Food and Beverage No VOCA funds can be used to purchase food and/or beverages for any meeting, conference, training, or other event. The only exceptions to this restriction are stated below: The location of the event is not in close proximity to food establishments. It should be a priority to try to secure a location near reasonably priced and accessible commercial food establishments; If not serving food will significantly lengthen the day or necessitate extending the meeting to achieve meeting outcomes; A special presentation at a conference requires a plenary address where there is no other time for sustenance to be attained; and 9

15 Other extenuating circumstances which necessitate the provision of food. These food and beverage restrictions do not apply to: Water provided at NO cost (the restriction does apply to any and all other refreshments, regardless of the size or nature of the meeting or event); and Direct payment of per diem amounts to individuals in a travel status under your organization s travel policy. Any exceptions to the purchase of food and/or beverages for any meeting, conference, training, or other event due to the circumstances outlined above require prior approval from CVSD. If an exception is approved by CVSD, the following restrictions will apply: Only one refreshment break a day is allowable and grantees are strongly advised to eliminate all refreshment breaks and breakfast; The cost of a refreshment break may not exceed 11.5% of the General Services Administration (GSA) Meals and Incidental Expenses (M&IE) rate for the locality; and Any meal provided must stay at or below 150% of the applicable per diem rate, including any hotel service costs. Grantees are strongly encouraged to stay at or below 100% of the applicable per diem rate. Grantees are subject to monitoring of adherence to the food and beverage policy. Grantees should maintain all necessary documentation to support any conference costs, or food and beverage expenses if prior approval granted by CVSD. Grantees are encouraged to identify alternative training methods, such as webinars and teleconferences, to acquire lower cost locations and venues, and to avoid the appearance of extravagant spending. These food and beverage policies supersede OJP s Financial Guide and the Food and Beverage Policy dated September 30, VII. UNALLOWABLE SERVICES, ACTIVITIES AND COSTS The following services, activities, and costs, although not an exhaustive list cannot be supported with VOCA grant funds. (NOTE: If you have a question regarding whether a cost is allowable, please contact your Grant Monitor for clarification.) A. Lobbying and Administrative Advocacy VOCA funds cannot support victim legislation or administrative reform, whether conducted directly or indirectly. B. Perpetrator Rehabilitation and Counseling Grantees cannot knowingly use VOCA funds to offer rehabilitative services to offenders. Likewise, VOCA funds cannot support services to incarcerated individuals, even when the service pertains to the victimization of that individual. 10

16 C. Needs Assessments, Surveys, Evaluations, Studies and Research VOCA program funds may not be used to pay for efforts conducted by individuals, organizations, task forces or special commissions to study and/or research particular crime victim issues. D. Prosecution Activities VOCA funds cannot be used to pay for activities directed at improving the criminal justice system s effectiveness and efficiency, such as witness notification, management activities and expert witnesses. Victim/witness protection costs and subsequent lodging and meal expenses are considered part of the criminal justice agency s responsibility and cannot be supported with VOCA funds. VOCA-funded staff cannot be used to provide these services. VOCA funds are to be used to expand or enhance the delivery of services to victims of crime. Services and costs that are related to normal prosecutorial activities, that is, activities that are required to be performed by the District Attorney in prosecuting criminal and civil cases, are not allowed. Examples of normal prosecutorial activities for which VOCA funds cannot be used include, but are not limited to, questioning of victims and witnesses, preparation of victim/witness/expert testimony, participation in Grand Jury, subpoenaed individuals, etc. E. Fundraising Activities Most victim assistance programs must do some fundraising, either by hiring a fundraising consultant or by using in-house staff. Whichever means you choose, remember that individual giving accounts for nearly 90 percent of all charitable contributions in America, and so should be a mainstay of support for your organization. However, VOCA funds may not be used to pay for fundraising or administrative staff expenses. This also includes VOCA funded personnel performing those activities. For example, volunteer coordinators who coordinate or organize fundraising events should not be charging these activities to VOCA. F. Indirect Organizational Costs Indirect costs are NOT allowable. Indirect costs are costs of an organization that are not readily assignable to the particular grant, but are necessary to the operation of the organization and the performance of the grant (i.e., information services, payroll costs, depreciation and administrative salaries). The costs of property liability insurance on buildings, capital improvements, security guards and body guards, property losses and expenses, real estate purchases, mortgage payment and construction may not be supported with VOCA funds. G. Reimbursement of Crime-Related Expenses (i.e., property loss) Reimbursing victims for expenses incurred as a result of a crime (i.e., insurance deductibles, stolen property replacement, funeral expenses, lost wages and medical bills) is not allowed. VOCA funds cannot be used to restore the financial losses suffered by victims of fraud. 11

17 H. Most Medical Costs VOCA funds cannot be used to pay for nursing homes, home care costs, in-patient treatment, hospital care and other types of emergency and non-emergency medical and/or dental treatment costs. VOCA cannot support medical costs resulting from victimization, except for forensic medical examinations for sexual assault victims. Forensic or medical examinations for sexual assault victims are allowable only to the extent that other funding sources (i.e., Oregon s Sexual Assault Victims Emergency Medical Response Fund, private insurance or public benefits) are unavailable or insufficient. Please note: it is permissible to use VOCA funds for short-term nursing home shelter or in home care for elder abuse or disabled victims for whom no other safe short-term resource is available. I. Victim Relocation Expenses Costs such as moving expenses, security deposits, ongoing rent and mortgage payments cannot be paid with VOCA funds, although staff time used to locate resources to assist victims is allowable. J. Administrative Staff Expenses Salaries, fees, and reimbursable expenses for administrators, board members, executive directors, consultants, coordinators, and other individuals, unless incurred while providing direct victim services, cannot be paid with VOCA funds. K. Development of Protocols, Interagency Agreements and Other Working Agreements Though these activities benefit crime victims, they are considered examples of the types of activities that grant recipients should undertake as part of their role as victim services organizations, which in turn qualifies them as VOCA grantees. L. Costs of Sending Individual Crime Victims to Conferences TIP: Presentations that are designed specifically for prevention or for educational purposes are not allowable under VOCA. However, if a staff person is not 100% funded by VOCA, they can conduct these activities with the remainder of their FTE. M. Activities Exclusively Related to Crime Prevention and Public Education Though public presentations are allowed for those who help crime victims identify their own victimization, general public education, prevention and awareness campaigns are not allowable. Allowable public information costs are limited to efforts describing the direct services under the grant and an explanation of how those services can be obtained (i.e., publication of pamphlets, brochures, etc). These materials, however, cannot be used for mass distribution as part of a broad public information effort. N. Purchase of Vehicles or Buildings Real estate purchases, mortgage payments, liability insurance on buildings, capital improvements, and construction may not be supported with VOCA funds. 12

18 O. Coordination of Community Efforts Coordination efforts, such as serving on task forces and commissions, qualify an organization to receive federal VOCA funds but are not activities that can be supported with federal VOCA funds. P. Non-Emergency Legal Services VOCA funds cannot be used to pay for non-emergency legal representation, such as divorces or civil restitution recovery efforts. Q. Audits for Public Agencies or Non-profit Organizations (under $500,000 in federal funds) VOCA will not pay the prorated share of audit costs, unless the grant recipient organization is a non-profit agency or institution of higher education and meets the single audit threshold of expending $500,000 or more in federal funds (from all sources including pass-through sub-awards) in the organization s fiscal year. Public agencies, such as an Office of the District Attorney, are not permitted to utilize VOCA funds for audits. Most public entities are required to have an audit, whether or not that public entity receives VOCA funds. Please refer to pages for further guidelines regarding audits. R. Costs Incurred Outside the Project Period Any costs that are incurred either before the start of the project period or after the expiration of the project period are not allowable, unless written approval is granted by the awarding agency (pre-agreement costs or no-cost extension). 13

19 SECTION 2 VOCA GRANT APPLICATION PROCESS I. TARGET POPULATIONS TO BE SERVED The Victims of Crime Act of 1984 requires each state to certify that priority will be given to programs serving specific categories of crime victims. The priority categories are: Domestic Violence Sexual Assault Child Abuse Previously Underserved populations, which may include, but are not limited to: - Violent crimes committed against any disabled person; - Survivors of homicide victims; - Victims of gang violence; - Victims of hate/bias crime; - Victims of intoxicated drivers; - Victims of violent crime committed by juvenile offenders; - Violent crimes committed against the elderly; - Violent crimes committed against non-english speaking residents; - Violent crimes committed against members of racial, cultural or ethnic minorities; - Violent crimes committed against residents of rural or geographically isolated communities; - Restitution services to victims; - Crime victims of offenders under parole and probation supervision; and - Other (an applicant may identify a particular population or category of crime victims that has not been addressed by VOCA funds and are in need of services. Supporting documentation must be included. General Assistance to all victims of crime Per federal requirements, ten percent (10%) of funds available to Oregon for VOCA sub-grant awards must be allocated to each of the following priority categories: domestic violence, sexual assault, child abuse and previously underserved priority categories. While General Assistance is not a federally mandated category, the VOCA Advisory Council has stipulated that an additional ten percent (10%) of funds available to Oregon for VOCA subgrant awards be allocated to a General Assistance category to enhance victims access to services. II. FUNDING CATEGORIES The term VOCA proposal or grant refers to both federal VOCA funds and the associated non-federal match included in the approved VOCA budget. All federal and match funds budgeted as part of the VOCA project must be utilized for direct services, unless and to the extent otherwise provided for, in this Handbook and as approved by the Oregon Department of Justice. The Oregon Department of Justice reserves the right to modify the award amount, request a modification of the entire proposal, specifically the programmatic goals and budget 14

20 items, with the selected applicant(s) prior to entering into a grant agreement. Every agency receiving an award should read the language of the grant agreement carefully. Should an award be made, by signing the grant agreement the grantee is agreeing to comply with the grant agreement terms for the funds for which they applied. If you would like a copy of the VOCA grant agreement language, an example is available on the DOJ CVSD website at: Historically, two types of VOCA grants have been distributed by CVSD; non-competitive (Basic grants) and competitive (Project grants). Those grants are identified within the next two sections. A. Non-Competitive Grants (previously referred to as Basic) Victim service programs eligible for the Non-Competitive Grants are those so designated by the Oregon Department of Justice. Non-Competitive Grants have been in effect with many individual grant recipient agencies for over ten years. Non-Competitive Grants are normally funded for the same services year after year and are intended to fund core agency services. The two applications for non-competitive funding are: 1. Joint DV/SA Request for Application (RFA): This application process is for nonprofit agencies/programs that specifically offer options for safety through a continuum of intervention and support services for victims of domestic violence, sexual assault, dating violence, and stalking. The agencies/programs are currently receiving grants directly from DOJ or DHS. The following grant sources are part of this consolidated application process: Oregon Domestic and Sexual Violence Services Fund (ODSVS) through DOJ CVSD; Victims of Crime Act (VOCA) Non-Competitive Grant funds for Domestic Violence and Sexual Assault services through DOJ CVSD; STOP Violence Against Women Act (VAWA) Formula Grant Program victim services funding through DOJ CVSD (formerly through Criminal Justice Services Division); DHS CFA Domestic Violence Fund including the state surcharge on marriage licenses (MLT fund), the Criminal Fines Account (CFA/DV) and the Federal Family Violence Prevention and Services Act (FVPSA) funding through DHS CAF; and DHS CFA Sexual Assault Victims Fund (CFA/SA) through Criminal Fines Account. Grantees receiving funds through the Joint Application process will submit an update application through the CVSD E-Grants system for the VOCA Non- Competitive Grant Application in Grantees are contacted by DOJ CVSD when the update application is released via the following webpage: 2. Prosecutor Based Victim Assistance Programs; Child Advocacy Centers; and General Victim Service Programs Non Competitive Request for Application: This application process is for government based, child abuse and general victim service agencies/programs providing intervention and support services to all victims of crime. The agencies/programs are currently receiving grants directly from DOJ CVSD. 15

21 Grantees with a current ( ) VOCA Non-Competitive Program Grant will submit a new application in the Oregon CVSD E-Grant system for B. Competitive Grants (previously referred to as Project) The VOCA Competitive Grant request for application is open to all agencies who meet the VOCA eligibility criteria. DOJ CVSD will issue VOCA Competitive grants for two (2) years: October 1, 2012 September 30, The maximum award shall be $90,000, excluding match. The Competitive Project process is subject to availability of funding. The VOCA Advisory Committee makes recommendations for project focus areas which are forwarded to the Attorney General, or designee, for final approval. Agencies applying under this grant opportunity, will submit their request for application through the online Oregon CVSD E-Grants system. Should you wish to learn more about CVSD E-GRANTS and view frequently asked questions please visit the DOJ website at: When the request for application is released, it can be located on the DOJ CVSD website: 16

22 SECTION 3 GRANTEE ELIGIBILITY REQUIREMENTS All agencies awarded a VOCA Non-Competitive and/or Competitive Grant must meet all of the following requirements: I. RECORD OF EFFECTIVE SERVICES Agencies are to demonstrate a record of providing effective services to crime victims. This includes having the support and approval of its services by the community, a history of providing direct services in a cost-effective manner, and financial support from other sources as well as meeting the eligibility requirements provided in this Section. To be eligible for VOCA funding, agencies that do not meet any of the standards in this Section, must demonstrate that at least 25% of their financial support comes from non-federal sources. II. CONDITIONAL AWARDS All grant awards are made conditional upon the timely completion of grant award documents. Funds are not considered obligated and will not be transferred until all required grant award documents have been signed by an applicant and by the Department designee. If grant award documents are not completed by an applicant within three months of the notice to the applicant of the intended award, DOJ CVSD has the authority to reallocate the funds awarded. In addition, an award may be made conditionally if the grantee is not current in reporting for any previous grant award; has fewer than two full years of operational history in providing services to victims of domestic violence and sexual assault; has not fully demonstrated the ability to successfully manage any previous Fund awards; has not demonstrated at least two prior years of program stability 2 ; or when other circumstances exist that require a further showing of applicant s ability to successfully manage an award. If one or more of these conditions exist, the applicant will be notified by DOJ CVSD that a conditional award has been issued. The award shall specify the conditions to be satisfied by the applicant and the date by which the conditions must be satisfied. Applicants who do not satisfy conditions of funding by the date specified will be contacted by their grant monitor to discuss next steps. See Section 6: pages of this Handbook for additional information on financial requirements. III. MATCH REQUIREMENTS The purpose of matching contributions is to increase the amount of resources available to the grant projects supported by VOCA grant funds. Please note that match must be provided for each grant funded through DOJ CVSD and must be specific to, and solely reported for only one 2 Definition of Program Stability for DOJ CVSD Grantees As used in the above section, a demonstration of program stability for CVSD funded applicants must include: a. An applicant's history of providing cost-effective direct services to victims of domestic violence and/or sexual assault; b. A clear indication of support for applicant's services from one or more community agencies or organizations familiar with the needs of victims to be served, as well as the caliber of services provided by the applicant. 17

23 grant. Matching contributions of 25% (cash or in-kind) of the total Federal VOCA funds (VOCA grant) are required for each VOCA funded grant and must be derived from non-federal sources. All funds designated as match are restricted to the same uses as the VOCA grant funds and must be expended within the grant period. Calculating the Match The match requirement is 25% of the federal VOCA funds requested. A way to double check the required match is to multiply the total VOCA project (federal funds and match) funds requested by 20%. The resulting figures are the required match amount: Example: Federal funds you want to receive from VOCA $40,000 Match: 25% of VOCA request + $10,000 TOTAL GRANT COST = $50,000 Cash match may include, but is not limited to: Unitary Assessment money; County or state funds (ODSVS, DHS Fund - only MLT and CFA funds); United Way funds; Private donations; or Any other non-federal money (VAWA or FVPSA funds cannot be used as match). In-kind match may include, but is not limited to: Donations of equipment, office supplies the value placed on loaned or donated equipment may not exceed its fair market value; Work space (pro-rated) the value of donated space may not exceed the fair rental value of comparable space and facilities in privately owned building in the same locality; and Volunteers monetary value of time contributed by professionals and technical personnel and other skilled and unskilled labor, as long as the service provided is a necessary part of the funded project. The value placed on donated services must be consistent with the rate of compensation paid for similar work in the grantee s agency and may include the costs of benefits. If the required skills are not found in the grantee s agency, the rate of compensation must be consistent with the labor market. In either case, benefits may be included in the valuation. CVSD does not require a certain hourly value for VOCA match, but leaves this determination to each grantee. For assistance in determining volunteer rates for your agency, visit: Record keeping for match requirements (must be verifiable from the agency s records): Match contributions qualify as VOCA allowable services or activities and conform to other provisions of the VOCA Program Guidelines from the Office for Victims of Crime. Match is subject to the same restricted uses as are the federal VOCA funds; 18

24 VOCA grantees must maintain records that clearly show the source, the amount and the period during which the match was expended. These records will be reviewed by a grant monitor at the time of the in-person site visit; The basis for determining the value of personal services, materials, equipment, and space must be documented; Volunteer services used as match must be documented and, to the extent feasible, supported by the same methods used by the grantee for its own paid employees. Suggestions for documenting volunteer time include calendars and volunteer timesheets; Matching funds may be used for any line item within the total budget (whether or not VOCA funds are within that line item) and are not limited to an item-by-item match. They may be credited to the grant by the quarter as they are accumulated or be reported as contributed; and Grantees are encouraged NOT to match in excess of the amount required, so as not to unnecessarily restrict resources that could be used for other purposes. E-Grants does not allow budgeting of match greater than $2.00. Exceptions to the 25% match requirement: For VOCA grantees that are Native American tribes or organizations located on reservations, the match is 5% of the total VOCA project (VOCA grant plus match). Key Points to remember regarding match: 1. Match must be provided for each grant and solely reported on one grant; 2. Match must come from non federal funds; 3. Match is restricted to the same uses as VOCA grant funds; and 4. Match must be 25% of the VOCA funds. IV. VOLUNTEERS All grantees must utilize volunteers to provide or support direct victim services unless compelling reasons exist to waive this requirement. A compelling reason may include a statutory or contractual provision that bars the use of volunteers for certain positions or the inability to recruit and maintain volunteers after a sustained and determined effort. Volunteers may include student interns. Please refer to Section 4: pages for more information. Please keep in mind that a volunteer program is required for agencies receiving VOCA funds. Reach out to your community it is a great way to enhance your program and spread the word about victim services! V. COORDINATED PUBLIC AND PRIVATE EFFORTS Agencies must promote coordinated public and private efforts to aid crime victims to ensure continuity of support to the victim and to avoid duplication of effort. Coordination may include, but is not limited to, serving on federal, state, local, or Native American task forces, 19

25 commissions and/or working groups or developing written agreements that contribute to better and more comprehensive services. Coordination efforts qualify an organization to receive federal VOCA funds but are not activities that can be supported with federal VOCA funds. VI. CRIME VICTIMS COMPENSATION PROGRAM ASSISTANCE The Crime Victims Compensation Program (CVCP) is operated by the Crime Victims Services Division of the Oregon Department of Justice. The purpose of CVCP is to reimburse innocent crime victims for certain out-of-pocket expenses, such as counseling, funeral costs, lost wages and/or medical expenses. VOCA fund recipients are required to assist victims in seeking available crime victim compensation benefits and to ensure that all agency service staff are familiar with CVCP. VOCA fund recipients must establish agency policies and procedures to identify clients who may be eligible for benefits and must assist clients in filling out applications, along with gathering necessary information and documentation. Agencies are required to maintain a supply of CVCP brochures and applications. Information and materials can be obtained by calling the CVSD office at (503) or by visiting the CVSD website at: CVCP provides quarterly training on CVCP guidelines and procedures at CVSD. A schedule can be found at: (general training link) (agenda). VII. NO CHARGE TO VICTIMS Programs are required to provide services to crime victims through the VOCA grant at no charge to the victim. Any deviation from this provision requires prior approval from DOJ CVSD. VIII. VICTIMS OF FEDERAL CRIMES Agencies must offer services to victims of federal crimes on the same basis as victims of state crimes. A victim of a federal crime is defined as a victim of an offense that violates a federal criminal statute or regulation. Federal crimes also include crimes that occur in an area where the federal government has jurisdiction, such as some Native American reservations, national parks, some federal buildings and military installations. Examples of other federal crimes are terrorism, bank robbery, some drug-related crimes, interstate or international kidnapping, mail or wire fraud, violation of a qualifying protection order under federal law and trafficking persons. I. CONFIDENTIALITY OF PERSONAL INFORMATION In order to ensure the safety of adult, youth, and child victims of crime, a grantee shall protect the confidentiality and privacy of persons receiving services. Grantee shall not disclose any personally identifying information or individual information collected in connection with services requested, utilized, or denied through Grantee s programs. Additionally, grantee shall not reveal individual client information without the informed, written, reasonably time-limited consent of the person (or in the case of an un-emancipated minor, the minor and the parent or guardian or in the case of persons with disabilities, the guardian) about whom information is sought, whether for this program or any other Federal, State, Tribal, or territorial grant program, except that consent for release may not be given by the abuser of the minor, person with disabilities, or the abuser of the other parent of the minor. The term personally identifying information, individual information, or personal information means individually identifying information for or about an individual victim of 20

26 domestic violence, dating violence, sexual assault, or stalking, including (1) a first and last name; (2) a home or other physical address; (3) contact information (including a postal, or Internet protocol address, or telephone or facsimile number); (4) a social security number; and (5) any other information, including date of birth, racial or ethnic background, or religious affiliation, that, in combination with any other non-personally identifying information would serve to identify any individual. If release of information described in the previous paragraph is compelled by statutory or court mandate, Grantee shall make reasonable attempts to provide notice to victims affected by the disclosure of information; and Grantee shall take steps necessary to protect the privacy and safety of the persons affected by the release of the information. Grantee may share (1) non-personally identifying data in the aggregate regarding services to their clients and non-personally identifying information in order to comply with Federal, State, Tribal, or territorial reporting, evaluation, or data collection requirements; (2) court-generated information and law-enforcement generated information contained in secure, governmental registries for protection order enforcement purposes; and (3) law-enforcement and prosecutiongenerated information necessary for law enforcement and prosecution purposes.. CONFIDENTIALITY OF RESEARCH INFORMATION Except as otherwise provided by federal law, no grantee receiving VOCA funds shall use or reveal any research or statistical information furnished under this program by any person and identifiable to any specific private person for any purpose other than the purpose for which such information was obtained in accordance with VOCA regulations. Such information, and any copy of such information, shall be immune from legal process and shall not, without the consent of the person furnishing such information, be admitted as evidence or used for any purpose in any action, suit, or other judicial, legislative or administrative proceeding. See Victims of Crime Act of 1984 codified at 42 U.S.C. 1060(d). These provisions are intended to ensure confidentiality of information provided by crime victims to VOCA funded counselors or agencies. It is clear that there is nothing in VOCA or its legislative history to indicate that Congress intended to override or repeal a state s existing law governing the disclosure of information that is supportive of VOCA s fundamental goal of helping crime victims. For example, this provision would not act to override or repeal, in effect, a state s existing law pertaining to the mandatory reporting of suspected child abuse. See Pennhurst School and Hospital v. Haldermann, et al., 451 U.S. 1 (1981). Furthermore, this confidentiality provision should not be interpreted to thwart the legitimate informational needs of public agencies. For example, this provision does not prohibit a domestic violence shelter from acknowledging, in response to an inquiry by a law enforcement agency conducting a missing person investigation, that the person is safe in the shelter. Similarly, this provision does not prohibit access to a victim service grant project by a federal or state agency seeking to determine whether federal and state funds are being utilized in accordance with funding agreements. I. COMPLIANCE WITH THE FEDERAL FUNDING ACCOUNTABILITY AND TRANSPARENCY ACT (FFATA) OF 2006 As of January 1, 2009, all recipients of Federal VOCA funds, and their sub-contractors, must comply with the Federal Funding Accountability and Transparency Act (FFATA) of The FFATA requires a single searchable website for each federal award of $25,000 or more over the 21

27 life of any sub-award (i.e., VOCA grant award period) that must be accessible by the public without cost. In order to satisfy this requirement, fund sub-recipients are required to have a Data Universal Numbering System (DUNS) number and to maintain a current registration in the Central Contractor Registration (CCR) database; in July 2012 the CCR will migrate to the System for Award Management (SAM). Prior to a grant agreement being issued for VOCA funds, all programs are required to demonstrate that they meet this criteria by providing proof of a DUNS number and current registration in CCR or SAM to DOJ CVSD. 1. First Steps: Your agency should verify whether or not it has a DUNS number and a current registration in CCR or SAM. NOTE: You will receive an notification from CCR when it is time to migrate your registration to SAM. If your agency does not have a DUNS number, and/or is not currently registered in CCR or SAM (after July 2012), it is imperative for you to begin these processes now due to the time required to complete these tasks. As of now, without a DUNS number and a current registration in CCR or SAM, CVSD will not be able to make an award of federal funds to an entity. 2. Requesting a DUNS Number To obtain a DUNS number, online, go to the DUNS registration website at: or call the special Dun & Bradstreet hotline at 1 (866) You will receive a DUNS number at the conclusion of your phone call. There is no cost associated with obtaining a DUNS number. Your DUNS number is required as part of registration with CCR. 3. Registering with Central Contractor Registry or System for Award Management Before registering with CCR, it is suggested that you review the CCR User's Guide and the Frequently Asked Questions, which are available on the CCR website at Note: Pull together all the information you will need before beginning the registration process. This could take you several weeks. Once you are ready to begin the online registration, allow minutes to complete. To register with CCR, go to Click on Start New Registration on the left Navigation bar. Complete the registration as explained. If your questions/concerns are still unanswered, please contact: CCR Assistance Center at (888) or (269) After July 2012, if you have a current CCR registration, your data will be migrated from CCR to SAM. When it is time to renew, you will do it in SAM. You will go to create a SAM user account, and follow the online instructions to validate and update your information. Before updating you registration with SAM, it is suggested that you review the frequently asked questions listed on ccr.gov CCR is Going Away -- What to Expect, the Quick Start Guide for Migrating Roles, and the new SAM website at 22

28 After July 2012, if you do not have a current CCR registration, you will register at the new SAM website, Note: Pull together all the information you will need before beginning the registration process. This could take up to a week. Once you are ready to begin the online registration, allow minutes to complete. Before registering it is suggested that you review the Quick Start Guide for Entities Interested in Being Eligible for Grants. You will go to new SAM website at create a Personal Account and Login, click on Register New Entity under Manage Entity on your My SAM page, and follow the online instructions. After July 2012, if your questions/concerns are still unanswered, please contact the SAM Help Desk at II. CERTIFIED ASSURANCES & OTHER CERTIFICATIONS VOCA grant recipients must assure and certify that they comply with all applicable provisions of the Victims of Crime Act of 1984, as amended, and all other applicable federal rules regulating grants. This includes VOCA, the Office for Victims of Crime Program Guidelines, and the Office for Justice Programs Financial Guide. Should an award be made, by signing the grant agreement, the grantee is agreeing to comply with the grant contract terms for the funds for which they applied. Please read the Certification language carefully in the grant agreement. A. Non-supplantation Federal funds must be used to supplement existing funds for program activities and must not replace those funds that have been appropriated for the same purpose. Supplanting will be the subject of application review, as well as pre-award review, post-award monitoring, and audit. If there is a potential presence of supplanting, the applicant or grantee will be required to supply documentation demonstrating that the reduction in non- Federal resources occurred for reasons other than the receipt or expected receipt of Federal funds. For certain programs, a written certification may be requested by the awarding agency or recipient agency stating that Federal funds will not be used to supplant State or local funds. Nonprofit agencies are not bound by non-supplantation rules. B. Civil Rights Compliance Upon award, each grantee is required to review and sign a Certification of Compliance with Regulations federal form from the Office for Civil Rights, Office of Justice Programs and comply with any of the applicable certification requirements. Each grantee is required to maintain statutorily required civil rights statistics on victims services by race, national origin, sex, age, and disability. Grantees must also permit access to documents and records to determine whether the grantee is complying with applicable civil rights laws. This requirement is waived when the grant recipient is providing a service such as telephone counseling where soliciting the information may be inappropriate or offensive to the crime victim. Civil rights statistics must be kept on file with other VOCA grant documentation and must correspond with each grant period. The information will be reviewed during onsite visits or at the request of the Federal Administrator of VOCA Funds of the Office for Victims of Crime. 23

29 Civil Rights Non-Discrimination Requirements All VOCA grant recipients must assure and certify that they comply with all applicable civil rights non-discrimination requirements of Title VI of the Civil rights Act of 1964, as amended, 42 U.S.C. 2000d et seq. (prohibiting discrimination in programs or activities on the basis of race, color, and national origin) Omnibus Crime Control and Safe Streets Act of 1968, as amended, 42 U.S.C. 3789d(c)(1) (prohibiting discrimination in employment practices or in programs and activities on the basis of race, color, religion, national origin, and gender); Section 504 of the Rehabilitation Act of 1973, 29 U.S.C. 794 et seq. (prohibiting discrimination in employment practices or in programs and activities on the basis of disability); Title II of the Americans with Disabilities Act of 1990, 42 U.S.C (prohibiting discrimination in services, programs, and activities on the basis of disability); The Age Discrimination Act of 1975, 42 U.S.C (prohibiting discrimination in programs and activities on the basis of age); and Title I of the Education Amendments of 1972, 20 U.S.C 1681 et seq. (prohibiting discrimination in educational programs or activities on the basis of gender). Compliance with Title VI of the Civil Rights Act of 1964, which prohibits recipients from discriminating on the basis of national origin in the delivery of services or benefits, entails taking reasonable steps to ensure that persons with limited English proficiency (LEP) have meaningful access to funded programs or activities. An LEP person is one whose first language is not English and who has a limited ability to read, write, speak, or understand English. To assist recipients in meeting their obligation to serve LEP persons, the Department of Justice (DOJ) has published a guidance document, which is available on the LEP.gov web site. CVSD encourages applicants and recipients to include within their program budgets the costs for providing interpretation and translation services to eligible LEP service populations. VOCA requires that no person shall be excluded from participation in, denied the benefits of, subjected to discrimination under, or denied employment in connection with any program or activity receiving funds under VOCA on the basis of race, color, religion, national origin, sex, age, or disability. In the event that a federal or state court or federal or state administrative agency, after a due process hearing, makes a finding of discrimination against a grant recipient on the grounds of race, color, national origin, sex, or disability, a copy of such findings must be forwarded to CVSD and to the Office for Civil Rights for the Office of Justice Programs. C. Comply with Certifications Regarding Lobbying; Debarment, Suspension and Other Responsibility Matters; and Drug-Free Workplace Requirements Each grantee is required to review and sign this federal form from the Office of Justice Programs and comply with any of the applicable certification requirements: 1. Lobbying Certification This certification must be completed at the time of accepting a grant award from the Oregon Department of Justice. This rule provides guidance on requirements that grant recipients shall meet in order to receive Federal funds. According to federal guidelines, a grantee entering into a grant agreement of $100,000 or over must certify that: 24

30 No federally-appropriated funds will be expended by grant recipients of a Federal award, cooperative agreement or grant to pay a person for influencing or attempting to influence an officer or employee of any agency, a member of Congress, an officer or employee of Congress, or an employee of a member of Congress in connection with any of the following covered Federal actions: the awarding of any Federal grant, the making of any Federal grant, the entering into of any cooperative agreement, and the extension, continuation, renewal, amendment, or modification of any Federal grant or cooperative agreement; and If any funds other than federal appropriated funds have been paid or will be paid to any person for influence of an officer or employee or any agency, a Member of Congress, an officer or employee of Congress, or an employee of a Member of Congress in connection with this federal grant or cooperative agreement, the undersigned shall complete and submit Standard Form-LLL, Disclosure of Lobbying Activities, in accordance with its instructions. 2. Debarment and Suspension Certification This certification must be completed at the time of accepting a grant award from the Oregon Department of Justice. The government-wide rule for debarment and suspension provides guidance on requirements that grant recipients shall meet in order to receive federal funds. 3. Drug-Free Workplace Certification This certification must be completed at the time of accepting a grant award from the Oregon Department of Justice. The government-wide rule for a drug-free workplace provides guidance on requirements that grant recipients shall meet in order to receive federal funds. In the case of a grant recipient who is an individual, that individual must certify to the agency that his or her conduct of award activity will be drug-free. If a grant recipient makes a false certification, the grant recipient is subject to suspension, termination and debarment. D. Equal Treatment For Faith Based Organizations Executive Order and the Equal Treatment for Faith-Based Organizations regulation, codified at 28 C.F.R. Part 38, require funding organizations to treat faithbased organizations (FBOs) the same as any other applicant or recipient of federal funding, neither favoring nor discriminating against FBOs in making and administering grant awards. FBOs must be allowed to retain their independence, autonomy, expression, and religious character when competing for federal funding. The Executive Order and regulation also prohibit recipient FBOs from using federal funding to engage in inherently religious activities, such as proselytizing, scripture study, or worship. Funded FBOs may engage in inherently religious activities; however, these activities must be separate in time or location from the federally assisted program. Moreover, funded FBOs must not compel program beneficiaries to participate in inherently religious activities. Funded faith-based organizations must also not discriminate on the basis of religion in the delivery of services or benefits. 25

31 VOCA contains express nondiscrimination provisions that prohibit all grant recipients from discriminating on the basis of religion in employment. Despite these nondiscrimination provisions, the Justice Department has concluded that, on a case-bycase basis, FBOs may continue considering religion when hiring staff, if it meets the following criteria: 1. The FBO demonstrates that its program for which it seeks federal funding is an exercise of religion; 2. The FBO demonstrates that requiring it to either forgo its religious preference in hiring or forgo the federal funding would substantially burden its exercise of religion; and 3. The funding entity is unable to demonstrate that applying the nondiscrimination provision to this FBO would both further a compelling government interest and be the least restrictive means of furthering this interest. The Justice Department may grant exemptions to the prohibition against hiring discrimination on the basis of religion on a case-by-case basis, unless there is good reason to question the truthfulness of the FBO. FBOs seeking an exemption to their prohibition against religious discrimination in hiring must complete, submit, and retain an original signed Certificate of Exemption for Hiring Practices on the Basis of Religion certifying to the following three provisions: 1. The FBO will offer all federally-funded services to all qualified beneficiaries without regard for the religious or non-religious beliefs of those individuals; and 2. Any activities of the FBO that contain inherently religious content will be kept separate in time or location from any services supported by direct federal funding, and if provided under such conditions, will be offered only on a voluntary basis; and 3. The FBO is a religious organization that sincerely believes that providing the services in question is an expression of its religious beliefs; that employing individuals of particular religious belief is important to its religious exercise; and that having to abandon its religious hiring practice to receive federal funding would substantially burden its religious exercise. FBOs seeking such an exemption should submit the original signed Certificate of Exemption to DOJ CVSD after receipt of an award. DOJ CVSD will forward the Certificate of Exemption to the Office for Civil Rights for consideration. For more information on the regulation, please see OCR s website at: E. Compliance with State Criteria and Victims Rights Grantees must abide by any additional eligibility or service criteria established by CVSD, including submitting financial, statistical, and programmatic information on the use and 26

32 benefits of VOCA funds. Every agency that receives VOCA funds is expected to make a reasonable effort to ensure that crime victims in Oregon are treated with dignity, fairness and respect in accordance with U.S. and Oregon constitutional and statutory laws, including victims rights. Grantees shall take appropriate action to inform crime victims of their rights and to assist victims in exercising those rights. III. DEMONSTRATES ACCESS TO EFFECTIVE SERVICES To ensure meaningful access to services for all victims of crime across the State, programs must be able to appropriately respond to requests for assistance (e.g. completion of compensation claims, emergency housing, child abuse medical assessments, etc.). In addition, those agencies whose primary services are focused on a specific area of victim assistance must be able to directly link victims whose needs may be beyond their expertise to the appropriate community partner agency. IV. MAINTAINS GOOD FISCAL MANAGEMENT Agencies will be able to maintain adequate funding, expend funds according to submitted budgets, keep financial records and comply with grant reporting requirements. Agencies with deficiencies in any of the aforementioned good fiscal practices may receive conditional grants and be required to submit additional information addressing those deficiencies before a grant is awarded. See Section 6: pages for complete financial requirements. V. MAINTAINS ADEQUATE INSURANCE COVERAGES A. Nonprofit Agencies Nonprofit agencies must obtain and maintain in full force the types of insurance outlined below throughout the duration and all warranty periods of an award period. Agencies must obtain the insurance from insurance companies or entities that are authorized to transact the business of insurance and issue coverage in the State of Oregon and that are acceptable to DOJ CVSD. Agencies must require and ensure that each of its subcontractors complies with these same insurance requirements. As evidence of the insurance coverages, agencies must furnish certificate(s) of insurance to DOJ CVSD. Insurance coverage required by this section must name the State of Oregon, Department of Justice, including its officers and employees as Additional Insureds, but only with respect to acts or omissions of the Grantee, its officers, employees or agents under a grant award or in the conduct or implementation of a VOCA-funded Project. Agencies cannot cancel, make a material change, make a reduction of limits, or not renew insurance coverage(s) without 30 days prior written notice to DOJ CVSD. 1. Workers Compensation. All employers that employ subject workers as defined in ORS , must comply with ORS and provide workers' compensation insurance coverage for those workers, unless the agency or the subcontractor meets the requirement for an exemption under ORS (2). 27

33 2. Comprehensive or Commercial General Liability Insurance. Agencies must have comprehensive or commercial general liability insurance covering personal injury and property damage arising from the conduct and implementation of a VOCA-funded Project. 3. Automobile Liability Insurance. If in the conduct and implementation of a VOCA-funded Project, an agency provides transportation for and/or transports individuals in automobiles, the agency must have automobile liability insurance, including coverage for owned, hired or non-owned vehicles, as applicable. 4. Professional Liability Insurance. If in the conduct and implementation of the Project, Grantee provides professional advice or services, Grantee shall obtain and maintain professional liability insurance covering any damages caused by an error, omission or any negligent acts related to the performance of any professional services to be provided under this Agreement. B. Intergovernmental Agencies Intergovernmental agencies must require and ensure that each of its subcontractors complies with the insurance requirements stipulated in the Subcontractor Insurance Requirements which is included as Exhibit E in the Intergovernmental Grant Agreement (See Appendix I for an example of Exhibit E). VI. COMPLIES WITH FINANCIAL, DATA AND OUTCOME REPORTING All agencies must comply with the Federal and CVSD reporting requirements including the timely submission of quarterly financial, common outcome measures and semi-annual narrative and statistical reports. See Section 5: pages for a complete description of reporting requirements. VII. SERVICES PROVIDED ARE CULTURALLY COMPETENT AND ACCESSIBLE Applicants will provide services that are culturally competent and accessible to the populations in their communities. Applicants will continue or begin an assessment and planning process to identify and prioritize community needs and agency responses. Cultural Competency Standards distributed by DOJ CVSD are a resource for this planning process. VIII. COMPLIES WITH TRAINING REQUIREMENTS All agencies receiving VOCA funds shall comply with the training requirements for VOCA funded staff. Domestic violence and sexual assault providers shall make provisions to attend a training that utilizes the Department of Human Service s domestic violence and sexual assault training requirements. All other grantees shall make provisions to attend the State Victim Advocate Academy (SVAA) training through the Crime Victim Assistance Network (CVAN). Training shall be complete within the grant cycle. 28

34 SECTION 4 VOCA MANAGEMENT AND OPERATIONS GUIDELINES I. INTRODUCTION These guidelines have been established to provide clarification for VOCA grant recipients, as well as to supplement information received from grant monitors and other sources. II. GUIDELINES FOR EMPLOYEE MANAGEMENT A. Staff Issues Only staff providing direct services to crime victims, along with persons who recruit, train and supervise volunteers utilized as part of the VOCA grant may be funded. Other paid staff can be funded only if it can be demonstrated that they are essential to support the delivery of direct services. For each position that is included in the VOCA budget, the grantee must notify CVSD (by phone, mail, , or fax) within thirty (30) days of any changes in the person filling the position. It is the responsibility of the District Attorney, or the Board of Directors of a VOCAfunded agency, to notify CVSD within thirty (30) days of any change in leadership within the program (i.e., Director). Accurate time/attendance records must be maintained for all positions budgeted under the grant. This includes salaried positions and any personnel (including volunteers) written into the budget attributed as federal funds or match. Adequate documentation and policies must be maintained within the VOCA file. Special care should be taken if a position is funded from more than one source. The Organization Details in the E- Grants system provides a framework for capturing this information and we urge you to update this information as necessary. Written personnel policies and procedures with regard to work hours, holidays, vacation, sick leave, overtime pay, compensatory time, termination, job descriptions and job qualifications must be available at the agency. In a nonprofit agency, the Executive Director of the agency will not serve as a member or Chair of the agency s Board of Directors. Volunteer coordinators are not allowed to coordinate or organize fundraising activities on VOCA time. 29

35 B. Volunteers 1. CVSD requests that volunteers be used for direct service work with victims, meaning that any activity directly related to the administration of the VOCA Grant, and/or the delivery of victim assistance services, is preferred. Examples include: Clerical/support services related to the administration of the grant (i.e., compiling semi-annual statistics) or services such as victim notification and correspondence; Accompanying victims to court and grand jury; Advocating for victims with other agencies; Providing information and referral; Advocating for release of property; Gathering client feedback; Crisis intervention; and Other standard advocate duties. 2. Programs can count the hours volunteers spend in training as match. This assumes that the training is directly related to victim assistance services. 3. A person can be a volunteer at two different programs. However, at any point in time, the program(s) and the volunteer need to be clear about who is responsible for directing the volunteer s work. The hours during which the grantee program directly supervises the volunteer s victim advocate activities may be counted. It is not allowable to count the same volunteer hours on more than one grant award. If a volunteer is supported by, or provides volunteer hours for, both VOCA and VAWA, the volunteer hours and activities should be appropriately divided between the two programs. 4. Paid agency employees may not perform their duties as volunteers. Practices that may not be considered volunteer time include unpaid overtime, oncall duties or un-reimbursed staff expenses, especially if these duties are explicitly stated in the employee s job description. 5. The agency must maintain proper documentation for all volunteer time reported as match. This should include time, attendance and service area records documenting VOCA eligible activities. 6. Examples of volunteering that can NOT be counted towards match: Fundraising; General office administration; Board membership (i.e., attending Board meetings); General public relations; and Lobbying. 30

36 7. Volunteer Hours While On-Call The value of the donated service may not exceed the rate your agency would pay an employee to provide the same level of service. For example, if two victim assistants provide the same service, but one is paid and the other is a volunteer, you could use the same rate per hour for the volunteer that you pay your employee, including the salary and benefits associated with the paid position. Similarly, if two victim assistants are considered on-call or carry a pager or cell phone, and provide a service as needed, you could use the same rate per hour for the volunteer that you would pay your employee for providing the same service. You may use the rate your agency would pay an employee to be on-call, or for carrying a pager, or cell phone. However, if your agency does not pay employees to be on-call, or to carry a pager or cell phone, then you would use the going rate in your area, for that service. Please check with other agencies in your area to determine what rate they pay their employees for providing an equivalent service. C. Criminal History Verification (Background Checks) A grantee shall obtain a criminal history record check on any employee, potential employee or volunteer working with victims of crime or having access to individual client identified information as follows: a. By having the applicant, as a condition of employment of volunteer service, apply for and receive a criminal history check from a local Oregon State Police Officer and furnish a copy thereof to Grantee; or b. As the employer, by contacting a local Oregon State Police (OSP) office for an Oregon only criminal history check on the application/employee/volunteer; or c. By the use of another method of criminal history verification that is at least as comprehensive as the OSP methods described in paragraphs a. and b., above. A criminal record check will indicate convictions of child abuse, offenses against persons, sexual offenses, child neglect, or any other offense bearing a substantial relation to the qualifications, functions or duties of an employee or volunteer scheduled to work with victims of crime. The grantee shall develop a policy or procedure(s) to review criminal arrests or convictions of employees, potential employees or volunteers. The review will examine: The severity and nature of the crime; The number of criminal offenses; The time elapsed since commission of the crime; The circumstances surrounding the crime; The subject individual s participation in counseling, therapy, education or employment evidencing rehabilitation or a change in behavior; and 31

37 A review of the police or arrest report confirming the subject individual s explanation of the crime. The grantee shall determine after receiving the criminal history check whether the employee, potential employee or volunteer has been convicted of one of the crimes described in this section, and, whether based upon the conviction, the person poses a risk to working safely with victims of crime. If the grantee intends to hire or retain the employee, potential employee or volunteer, the grantee shall document in writing the reasons for hiring or retaining the individual. These reasons shall address how the applicant/employee/volunteer is presently suitable or able to work with victims of crime in a safe and trustworthy manner, based on the policy or procedure(s) described in the preceding paragraph of this section. The grantee will place this explanation, along with the applicant/employee/volunteer s criminal history check, in the employee/volunteer/ personnel file for permanent retention. D. Other State and federal VOCA Guidelines (rules, restrictions and reporting requirements) apply to paid and volunteer staff only to the extent such positions are included in the VOCA grant budget, whether supported with federal VOCA or local match funds. The following are illustrations: The salary and benefits for a full-time legal advocate are fully funded with federal VOCA funds. The entire position is subject to all VOCA requirements. Half of the salary and benefits for a full-time legal advocate are paid for with federal VOCA funds and half is included in the VOCA grant as match (source of the match is United Way funds). The entire position is subject to all VOCA requirements. Half of the salary and benefits for a full-time legal advocate are paid for with federal VOCA funds. The other half is not part of the VOCA grant as match. Only the hours charged to the VOCA grant are subject to VOCA requirements and only clients served and services provided for that portion may be included in VOCA grant reports. Volunteers provide an agency with a total of 5,000 hours of services (valued at $14 per hour) but only 1,000 hours of those volunteer hours are included as in-kind match. Only the 1,000 hours of volunteer time ($14,000 as the match contribution) reported are subject to VOCA requirements. III. GUIDELINES FOR CONTRACTUAL SERVICES Once an agency has been awarded a VOCA grant, those VOCA funds cannot be sub-granted or contracted out to another organization for the completion of grant activities. VOCA grantees are prohibited from using a majority of VOCA funds for contracted services, which contain administrative, overhead and other indirect costs included in the hourly or daily rate. Examples of allowable contractual services include: assistance in filing restraining orders or establishing emergency custody/visitation rights (the provider must have demonstrated a history of advocacy on behalf of domestic violence victims), the services of a play therapist and sign 32

38 language and/or interpretation for the deaf or for crime victims whose primary language is not English, and when a memorandum of understanding includes an exchange of grant funds between collaborative partners. These types of services may be funded through a VOCA grant, but must be identified as a contractual service on the application. Where the intent to award contracts is known and expressly stated as part of the application, the approval may be considered granted if these activities are funded as proposed. All such arrangements must be formalized in a contract or other written agreement between the parties involved. Compensation for consultant services should be reasonable and consistent with that paid for similar services in the marketplace. Compensation in excess of $450 per 8 hour day, or $56.25 per hour, requires prior approval from CVSD. The contract or other written agreement must not affect the grantee s overall responsibility for the duration of the grant and accountability to the Oregon Department of Justice. A signed copy of any contract must be uploaded in E-Grants during the application process. WHEN DO I NEED A CONTRACT? A CONTRACT is required when VOCA funds will be used by the grantee to pay for professional services that are outside your agency. Anytime a financial transaction will occur between the agency and another entity or person. The services must be allowable under the VOCA guidelines. Examples include: collaborative projects, support groups, therapy services and emergency legal services. The contract must include the grant policies and the flow-through requirements that are applicable to the contractor or other secondary recipient, other policies and procedures to be followed, and the cost principles to be used in determining allowable costs. In addition, the following elements should be considered when executing an Independent Contractor Agreement: Parties to the Agreement Term of the Agreement Scope of Work and Deliverables Contractor Compensation Independent Contractor Relationship Representations and Warranties Indemnification Confidentiality Insurance Requirements Amendments Signature of Authorized Representatives See Appendix D for a sample format of an Independent Contractor Agreement. 33

39 IV. GUIDELINES FOR A MEMORANDUM OF UNDERSTANDING A Memorandum of Understanding (MOU) is required of an agency when they have applied for funds with partnering organizations. The MOU provides documentation that demonstrates the organizations have consulted and coordinated the responsibilities of their grant activities. The following elements should be considered when constructing an MOU: Describe each partner agency; State the purpose of the MOU; Clearly describe the agreed upon roles and responsibilities each organization or agency will be providing to ensure project success. The roles and responsibilities should align with project goals, objectives and target outputs; Identify the staff responsible for completing the specific responsibilities, this should include meeting CVSD reporting requirements; Describe how the collaboration/partnership benefits the project; Describe the resources each partner would contribute to the project. This can be a time commitment, in-kind contributions, or grant funds (e.g., office space, staff, training, etc.); Provide a statement that the lead agency accepts full responsibility for the performance of the collaborative organizations/agencies; and The MOU must be signed by all partners. Signatories must be officially authorized to sign on behalf of the agency and include title and agency name. See Appendix E or a sample format of a Memorandum of Understanding. V. GUIDELINES FOR TRAINING AND TRAVEL A. Travel/Mileage for Direct Services Travel costs for paid and volunteer staff must be for the purpose of providing direct services to victims. This may include reasonable costs for transporting victims in connection with the provision of direct services. The travel must take place within the grant period (i.e., between the grant s beginning and ending dates). All travel expenses must be documented and retained in the appropriate VOCA file. B. Training Related Travel VOCA funds can support costs such as travel, meals, lodging and registration fees to attend victim advocacy-related training within the state or a similar geographic area. Programs should first look for available training within their immediate geographical area, as travel costs will be minimal. Training within Oregon need not be approved in advance, as long as training has been approved in the grant budget. It is the agency s responsibility to ensure that training costs comply with VOCA restrictions. It should not be assumed that a specific training event identified in a budget proposal is necessarily appropriate for VOCA funding. Therefore, it is advisable that agencies confer with CVSD regarding the appropriateness of specific training events to avoid having reimbursement for these costs rejected at a later date. 34

40 C. Training Outside of Oregon When needed training is unavailable within the grantee s immediate geographical area, VOCA funds may support training outside of the geographical area. For example, grantees may benefit by attending national conferences that offer skills-building training workshops for victim assistance providers. Because federal VOCA guidelines discourage the use of VOCA funds outside the grantee s immediate geographic area, training outside Oregon must be approved by CVSD in advance, unless a specific training is approved at the time of the grant award. When requesting out of state training in advance, the following must be provided: Agenda; Reason for attending; Description of topics sufficient to establish that training is for direct victim services skill development; Itemized costs; and Reasons why comparable training within the state is unavailable. D. Unallowable Costs Related to Training Training unrelated to direct victim services, such as grant writing, fundraising, lobbying or general administration/management; Training of persons who do not provide direct victim services, such as Executive Directors, administrative or clerical assistants and board members; Costs associated with a grantee providing training to individuals from other organizations (staff from other organizations can be invited to attend training activities that are held for the grant recipient s staff, if no additional costs will be incurred by the VOCA funded grantee); Development of training manuals, extensive training materials or curricula; Costs of sending individual crime victims to conferences; Sponsorship of regional or statewide conferences; and Food or beverages (with extremely limited exceptions, refer to Food and Beverage on page 9). Any training outside of Oregon must be pre-approved by your grant monitor and budgeted in your grant. VOCA funds cannot be used to cover lodging if the Government rate is not available. 35

41 SECTION 5 REPORTING REQUIREMENTS I. OVERVIEW Grantees must collect and report certain data in order to comply with both state and federal Performance Report requirements. Grant recipients are strongly encouraged to develop data collection systems that offer maximum flexibility. Unless otherwise stated, all data collected and reported for VOCA reporting purposes must be limited to those activities and services directly funded by the VOCA grant and not to overall agency activities. It is permissible, with CVSD approval, to pro-rate certain information based upon a reasonable, accurate and logical basis i.e. FTE funded by the grant. All grantee reporting will be completed and submitted through the CVSD E-Grants system. II. REPORTING REQUIREMENTS October 1 st January 1 st Reporting Period December 31 st March 31 st October 1 st March 31 st Type of Report Due Quarterly Financial Report, Common Outcome Measures Report Quarterly Financial Report, Common Outcome Measures Report Narrative Report, Goals/Objectives & Performance Measures Semi-annual Statistics April 1 st June 30 th Common Outcome Quarterly Financial Report, Measures Report July 1 st September 30 th Common Outcome Quarterly Financial Report, Measures Report April 1 st September 30 th Entire Grant Period Narrative Report, Goals/Objectives & Performance Measures Semi-annual Statistics Final Goals/Objectives & Performance Measures Report Due No Later Than: January 31 st April 30 th April 30th July 20 th October 31 st October 31 st October 31st A. Quarterly Financial Reports (QFRs) CVSD operates funding for the VOCA Grant Program on a reimbursement basis, meaning that grant funds are paid to grantee agencies after expenditures have been made. Payments to grantees are made when CVSD receives a Quarterly Financial Report (QFR). The QFRs that are due by April 30 th and October 31 st must be accompanied by 36

42 the quarterly reporting requirements as well as the required semi-annual statistics and narrative. IMPORTANT INFORMATION REGARDING PAYMENTS QFRs submitted without the accompanying required quarterly and/or semi-annual reports will not be processed for reimbursement until all reports have been submitted and reviewed. It is the responsibility of the grantee to respond to all requests for edits or information made by DOJ CVSD grant unit staff in a timely manner. Failure to comply will delay payment. Grantees may not obligate funds, order goods, enter into contracts, or request purchase orders prior to the start of the grant period. Reimbursement payments can be processed as quickly as two weeks or take up to one month. This is due to the fact that the drawing down of federal funds is done two or sometimes three times per month. The Federal government has a black out on draws the last five days of each month. A draw made on a Wednesday of one week will arrive at DOJ the following Tuesday and it is expected that payments can be issued by Friday. QFRs may be submitted in E-Grants by organization members with the role of Authorized Official, Agency Administrator, or Financial Officer. It is the responsibility of the grantee agency to ensure that only those organization members authorized to submit a QFR do so. Grantees must maintain supporting documentation for each QFR submitted. OTHER IMPORTANT NOTES ABOUT QFRS: 1. Expenditures Expenditures should be reported for actual approved and incurred expenses, as opposed to dividing the total amount of the grant into equal requests for reimbursement for the length of the grant. While this is a convenient method of requesting payment it may not necessarily accurately represent the expenditures charged to a grant. All expenditures must coincide with the current approved budget submitted, which will be one of the following: - the original budget submitted with the grant application through E-Grants; - an amended budget submitted through E-Grants; CVSD reimburses expenses quarterly unless otherwise agreed between CVSD and the grantee. Expenditures must be reported in the quarter in which the expenses were incurred. CVSD reimburses only actual and allowable expenditures for goods and services purchased during the grant period. CVSD does not reimburse items that are not in the approved budget. CVSD may withhold funds for any expenditure not budgeted or in excess of approved budget amounts. Failure of the grantee to operate the program in accordance with the approved budget may result in suspension and/or termination of the grant agreement. 37

43 CVSD will hold a grantee accountable for any overpayment, audit disallowances, or any other breach of grant agreement that results in a debt owed to the federal government. 2. CVSD E-Grant: QFR The E-Grant QFR will show page errors if any of the following is entered: o Total costs in the Personnel category (Salary + Personnel Expenses) in excess of the budgeted amount for the Personnel category. o Unbudgeted costs totaling more than $500 in the Services and Supplies and Other Costs categories. o Costs in any unbudgeted subcategory. o No match was entered and no explanation was provided. All requests for budget changes must be made prior to expending any funds. It is the responsibility of the grantees to adhere to the approved budget as referenced in the grant agreement, or to request a budget amendment. The main point to remember is that at no time may a budget modification change the scope of the original grant agreement. 3. Attachments Copies of check stubs, timesheets, accounts, ledgers, or other supporting documentation should NOT be submitted with the QFRs. The documentation must be separated by each budget category with the amounts clearly identified. These records will be verified during a programmatic and financial site visit. 4. Advances In special circumstances, checks may be issued in advance, but not for more than ten percent (10%) of the VOCA funds awarded in the grant, and not for more than the grantee s estimate of the amount of funds needed for a maximum of 30 days. Please contact your grant monitor if you believe this may be needed and be prepared to provide an explanation for requesting an advance. 5. Unliquidated Obligations (Cash or Accrual Basis) Agencies may complete QFRs based on either accrual or cash principles. Cash basis is the method of reporting revenues and expenses when cash is actually received or paid out. Accrual basis is the method of recording revenues in the period in which they are earned, regardless of when cash is received, and reporting expenses in the period when the charges are incurred, regardless of when payment is made. On occasion, agencies may incur obligations or encumber funds toward the end of a grant period for which payment cannot be made until after the grant period has ended. In such cases, agencies should only report the actual expenditures paid during the reporting period. Obligations made prior to the end of the grant period, but not yet paid, must be reported on a separate statement which details the encumbered, but 38

44 unpaid, obligations charged to that grant award. Agencies will then have an additional 30 days to pay those obligations and report the expenditure on a final QFR. CVSD E- Grants allows the grantee to submit an additional final QFR to accommodate for this should it occur. In most instances, these types of unliquidated obligations will be due to accrued payroll expenses or, on rare occasions, an approved operating expense item, which had been ordered by the end of the grant period but not yet paid. This procedure may not be used to retroactively charge off previously unreported expenses in order to fully expend the VOCA grant award. 6. Final (Closeout) QFR Agencies have 30 days after the end of the last or final reporting period for any VOCA grant (no later than October 31 st ) to report expenses, request reimbursement and reconcile any discrepancies. If a grantee determines that VOCA funds will not be spent by the end of the grant period, a request for an extension must be submitted prior to the end of the grant period; otherwise, funds will be automatically deobligated and will no longer be available to the grantee. See pages of this section on redirects and extensions. B. Semi-Annual Performance Reports 1. Statistical Report Federal policy requires VOCA grantees to report statistical data on a semi-annual basis. This report will be completed in CVSD E-Grants. A Statistical Report must be submitted for each VOCA grant. Grantees must be able to distinguish between new and ongoing clients, on at least a monthly basis, to make collection for the correct reporting period easier. It is essential that the proper data be collected and reported; such data will be used to comply with both state and federal requirements. Grantees must carefully consider who their VOCA grant clients are in order to accurately collect and report relevant data. In general, clients are identifiable individuals who receive direct services by the staff resources reflected in the VOCA grant budget. Pro-Rating Statistics: All statistical data must be as accurate as possible. If the agency collects program wide statistics, pro-rating the statistics by the FTE of direct service staff funded by a specific grant would accurately represent the number of victims served and services provided by grant. The following should be taken into account when determining how to collect VOCA statistics: Contacting the public individually, in groups, in person or otherwise, with information about the availability of services may be an important outreach activity, but does not constitute the actual provision of direct services; persons so contacted are not clients unless they actually receive the direct services offered through the VOCA grant; and 39

45 Clients must be individually identifiable in order to ensure that data is unduplicated and to collect the necessary civil rights compliance information. The only exception is Number of Phone Contacts. The following information is required for the Statistics Report (titled Victims of Crime Act (VOCA), State Performance Report, Victim Statistics Report ): 1 st Chart (Type of Victimization): Unduplicated number of victims served by the VOCA grant by type of crime; and 2 nd Chart (Type of Services Provided): Number of services provided to victims. A service is counted each time a client is provided such a service during a given report period. The following are examples of unduplicated data: VOCA grantee provides services to a victim on October 15, 2012, January 25, 2013 and June 7, This client will be counted as a victim only once on the Performance Report, unless the person is the victim of another crime. VOCA grantee provides services to a victim on November 16, 2012, December 5, 2012 and February 15, While this client is counted once as a victim on the Statistics Worksheet, the services are counted each time a service is provided during each time period. A client attends 10 weekly support groups between November 12, 2012 and February 22, This client is counted only once as a victim, but can be documented as receiving ten (10) Group Treatment/Support. A client attends 10 weekly support group sessions between November 19, 2012 and July 12, This client is counted six (6) times as receiving Group Treatment/Support on the Statistics Worksheet for the period of October 1, 2012 March 31, 2013, and four (4) times as receiving Group Treatment/Support on the Statistics Worksheet for April 1, 2013 September 30, See Appendix A for further information and service definitions on the Statistics Report. Note: If a project grant has been extended, a final statistical report covering the duration of the extension must be submitted within 30 days of the grant closing. 2. Narrative Report Federal regulations require that each grantee must submit a semiannual narrative summary. Semi-annual narrative reports are not a substitute for other specifically required report information (i.e., reporting staff turnover, approval of specific expenditures, etc.). The narrative will be completed in CVSD E-Grants and will include the following information. Information pertinent to the six-month reporting period ending either March 31 st or September 30 th of each year; Any new issues that hinder victim assistance programs in GO AHEAD BRAG A LITTLE! Even if you feel that some information may not be pertinent to what is being requested in the semi-annual report, go ahead and share it. Your grant monitors find it interesting and useful to share with our federal grant monitor or other VOCA funded programs! 40

46 assisting crime victims in applying for crime victim compensation; Efforts to promote coordinated services; Efforts to serve federal crime victims; Notable activities to improve the delivery of services ( i.e., needs assessments, training, etc); At least one anecdote or case history illustrating ways in which VOCA funds have been used to assist crime victims; and Emerging issues or trends. 3. Goals, Objectives and Performance Measures Report (Competitive grants only) Reporting progress achieved on the performance measures is required. CVSD E- Grants has a specific reporting form to respond to progress on the Competitive grant goals, objectives and performance measures. When submitting the final goals, objectives and performance measures report, state the final performance measures achieved for the entire grant period and, if any target outputs or short term outcomes are not achieved, provide an explanation. Note: If a Competitive grant has been extended, a final narrative and goals, objectives and performance measure report covering the duration of the extension must be submitted within 30 days of the grant closing. 4. Client Feedback on Common Outcome Measures All VOCA grant recipients are required to collect feedback on services provided using the common outcome measures as the vehicle for collection. The client feedback will not be tied to the specific, VOCA funded project, but rather to all victim services provided by the program. Programs are asked to collect client feedback from at least 10% of appropriate clients with the goal of a 90% positive response. Programs may use Client Feedback Forms already in use in their agency. However, all programs are required to include the following measure that will be common across all VOCA funded programs: The program provided me with services that helped me make informed choices about my situation. In addition, programs must ask the following appropriate two discipline specific measures: For programs serving primarily Domestic Violence or Sexual Assault victims: 1. After working with this agency, I have some new ideas about how to stay safe. 2. After working with this agency, I know more about resources that may be available, including how to access them. For programs serving all types of victims of crime (including Prosecutor Based Victim Assistance Programs): 41

47 1. As a result of the information I received from the Victim Assistance Program, I better understand my rights as a victim of crime. 2. The information given to me by the Victim Assistance Program helped me better understand the criminal justice system process as it relates to my case. For programs serving primarily victims of child abuse: 1. The program staff treated my family with sensitivity and respect. 2. The program staff was supportive in helping me to access recommended treatment services for my child and family. Grantees are only obligated to survey appropriate clients, and should specify which clients will be surveyed via an internal, agency policy. For example, no clients in crisis would be appropriate, whereas support group clients, clients exiting shelter, or clients receiving follow-up services may be more appropriate. The forms are due quarterly, at the same time as the QFRs. Please contact your grant monitor if you are unsure of which set of questions to include on your client feedback form. III. NON COMPLIANCE WITH REPORTING All DOJ grant agreements provide that grantees who fail to meet any of the reporting requirements included in this section (financial, narrative, statistical, or outcome measures) shall be considered to be in default under the agreement. In such a case, DOJ has the right to end the grant. DOJ may also reduce the award proportionately to the period for which reports were not submitted in a timely manner. IV. OTHER REQUIRED COMMUNICATION A. Request for Amendments An amendment request is used to request programmatic and/or financial changes associated with a grant award as they occur during the grant cycle. Consider the following when requesting an amendment: At no time may a program or budget modification change the scope of the original grant agreement. Funds may only be moved and spent within the scope of the approved services. Budget revisions do not change the total amount of funding available for the grant. If a grantee determines that any modification of the approved budget or the extension (extensions apply to competitive grants only) of a grant period is necessary, a request should be made in E-Grants using the Amendment Request form. The grantee must obtain approval from CVSD for any amendment requests prior to the change being implemented. All amendment requests must be received at least 45 days prior to the end of the award period to be considered during the final quarter of a grant award. 42

48 Requests submitted after the project end date or those that would require retroactive approval shall be denied, unless by exception of the CVSD Victim Response Section Manager. CVSD will review each amendment request and will approve on a case-by-case basis. 1. Budget Amendments A budget amendment request is required for any of the following circumstances: Redirection of funds in or out of the Personnel category;* OR Movement of funds that totals more than $500 in the Services and Supplies or Other Services categories; OR Movement of funds to any unbudgeted category; OR Extension of the project period (not applicable for non-competitive grants). * Budget category is defined as being either Personnel, Services and Supplies or Other Services and the individual budget line items contained within. Budget Amendment Documentation: The following information must be submitted when completing a formal budget amendment request: A completed Amendment Request form in E-Grants; A Personnel budget amendment request form; and/or A Services and Supplies and Other Costs Budget Amendment Request form. Both the Personnel and Services/Supplies and Other Costs amendment forms can be downloaded from the Amendment Request form in E-Grants and must be uploaded back on to the Amendment Request form once completed. If approved, CVSD staff will make the requested changes to the grantees budget in the E- Grants system and the grantee will be notified of the approval via a system notification in E-Grants. Once approved, all subsequent QFRs will automatically contain the amended grant budget. Grantees will not be able to submit QFRs while an amendment request is in process. 2. Program Amendments While not an inclusive list, the following changes will require a program amendment: Modifying the approach, or scope of any component of the program. Making any change in collaborative partnerships. Adding, deleting, increasing, or decreasing an activity or goals, objectives or performance measures. When requesting a program amendment, a detailed explanation and justification will be required on the Amendment Request form in E-Grants that includes a complete description of the requested change and the effect the change will have on the project. 43

49 Once the grantee has received written approval of a performance or project amendment from CVSD, all future progress reports submitted must reflect any revised goals, activities, and/or performance measures. 3. Deobligated Funds: If funds are not expended by the end of the grant period, DOJ CVSD will deobligate the remaining funds from the grantee. A letter will be sent to the grantee informing the grantee that funds have been deobligated and the grant is closed. Should grant funds not be expended, only competitive grants have the option to extend the original grant period by completing the amendment process as described in this section. B. Achievement of Operational Status/Grant Commencement Each federally funded grant not achieving operational status within sixty (60) days of the beginning date of the grant period listed in the grant must submit a letter to DOJ CVSD describing: steps taken to initiate the grant; reasons for the delay; and the projected operational date. If the operational status is not achieved within ninety (90) days of the beginning of the grant period, the grant recipient must submit a second letter explaining the additional delay in implementation. The DOJ CVSD may, after reviewing the circumstances, elect to terminate the grant and redistribute the funds. The grantee must establish and maintain program records that document that grant activities are in compliance with the approved budget narrative. Such records must be readily available for review at the time of a site visit. This is included in your VOCA grant agreement(s). C. Termination of a Grant A grantee must immediately notify DOJ CVSD should they need to terminate their grant agreement (i.e., program closure). More information on termination by grantee or grantor (DOJ) can be reviewed on the sample grant agreement on the DOJ CVSD website at: 44

50 SECTION 6 FINANCIAL REQUIREMENTS I. OFFICE OF JUSTICE PROGRAMS (OJP) FINANCIAL GUIDE The Oregon Department of Justice, as State Administrator of VOCA, and the VOCA grant recipient, has an ongoing responsibility throughout the grant period to faithfully uphold the public trust which accompanies the authority to expend public funds. Recipient agencies will therefore establish and maintain fiscal control and accounting procedures, which assure that funds available for grants are properly disbursed, adequately controlled and accounted for in a separate account. All organizations that receive VOCA victim assistance funds must adhere to the financial and administrative provisions set forth in the OJP Financial Guide as implemented by DOJ CVSD. The guide is available via OJP s website at: II. OMB CIRCULARS/CODE OF FEDERAL REGULATIONS PERTAINING TO FISCAL REQUIREMENT It is the responsibility of the recipient agency to comply with the federal guidelines contained in the appropriately relevant Circulars. Copies of the Office of Management and Budget (OMB) circulars may be obtained from the addresses shown below. The Office of Management and Budget th Street, NW Washington, DC Administrative Requirements OMB Circular A-102: Grants and Cooperative Agreements with State and Local Governments. This Circular establishes standards for administration of grants with state and local government agencies. 2 CFR Part 215 formerly known as OMB Circular A-110: Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Nonprofit Organizations. This Circular establishes standards for the administration of grants to institutions of higher education, hospitals, and other nonprofit organizations. Cost Principles 2 CFR Part 220 formerly known as OMB Circular A-21: Cost Principles for Educational Institutions. This Circular establishes principles and standards for determining costs applicable to grants and contracts with educational institutions. 2 CFR Part 230 formerly known as OMB Circular A-122: Cost Principles for Nonprofit Organizations. This Circular establishes principles for determining costs of grants, contracts, and other agreements with nonprofit organizations. 45

51 2 CFR Part 225 formerly known as OMB Circular A-87: Cost Principles for State, Local and Indian Tribal Governments. This Circular establishes principles and standards for determining costs applicable to grants and contracts with state, local and Indian tribal units of government. Audit Requirements OMB Circular A-133: Audits of States, Local Governments, and Nonprofit Organizations. This Circular covers audit requirements for states, local governments, and nonprofit institutions. Common Rules: Uniform Administrative Requirements for Grants and Cooperative Agreements to State and Local Governments, 28 CFR Part 66. This Common Rule contains government-wide fiscal and administrative conditions governing federal grants and cooperative agreements and sub awards to state, local, and Indian tribal governments. Units of government and other organizations receiving federal financial assistance from the State shall adhere to applicable State laws and procedures. Grantees shall also adhere to any fiscal procedures established by DOJ CVSD. The federal CFDA number for VOCA funded programs is III. AWARD REQUIREMENTS A. Standards for Financial Management Systems All grantees are required to establish and maintain grant accounting systems and financial records to accurately account for awarded funds. When applicable, these records shall include both federal funds and all matching funds of state, local, and private organizations. Grantees shall expend and account for grant funds in accordance with state laws and procedures for expending and accounting for their own funds. 1. Accounting Systems Each grantee is responsible for establishing and maintaining an adequate system of accounting and internal controls. Each grantee is also responsible for ensuring that an adequate system exists for any subcontractors, when applicable. The grantee is free to use any accounting system that the grant recipient has established if the system meets the following minimum criteria: Each grant should be accounted for separately. Each grant award is regarded as coming from a separate fund source and should be accounted for as such. All grant records should reflect the grant number listed on the award documents; Entries in the accounting records should refer to manual documentation that supports the entry and which can be readily located; Receipts should be classified by source of funding (i.e., the name and number of the grant to which the associated costs have been charged). As a matter of convenience, grantees are encouraged to use the grant award number assigned to 46

52 the grant by DOJ CVSD, unless currently existing agency coding structures prevents this practice. If costs attributable to the grant program include those from sources other than the federal grant, such as match, donations, income earned by the grant, or funds from other sources, this should be clearly noted on receipts; Expenditures should be classified by the budget categories included in the grant application. All expenditure documents, regardless of type, must include the assigned grant number. Non-federal matching funds required at the grant level must be classified in these same budget categories; The accounting system must be such as to provide adequate information for the prompt and accurate submission of QFRs; The accounting system should be integrated with an adequate system of internal controls to safeguard the funds and assets covered, check the accuracy and reliability of accounting data, promote operational efficiency and encourage adherence to prescribed management policies. The internal controls should be documented in written procedures and be followed consistently; The accounting system should include a system of property records for all equipment. At a minimum this should include information on the acquisition date, serial numbers, equipment value and funding source(s) used to obtain the items (please refer to Appendix B for more information); All required financial records shall be maintained for three years from the date of the end of the federal grant period or until all questions arising from audits have been resolved, if questions cannot be resolved within three years; and A file shall be kept on each VOCA grant. The file should reflect the grant number and contain at least the following items (these items may be retained in E- grants, when feasible, or in a hard copy file): a. Grant award documents; b. Grant amendments or any changes to the grant award; c. Supporting documentation of any expenditures pertaining to this grant (i.e., original receipts, invoices, etc.); d. Documentation of employee and volunteer timesheets as pertains to the grant; e. Signed copies of any contract supported by the grant; f. Documentation for grant match; g. Documentation of received VOCA reimbursement checks; h. Property records of equipment purchased with VOCA grant funds, including serial numbers; and i. Other pertinent information (i.e., correspondence with grant monitor, memos from DOJ CVSD, training information, etc.) Additionally, it is recommended that the following items are retained with those listed above: program application submitted for VOCA funds, VOCA Grant Management Handbook, reporting requirements, monthly revenue and expenditure reports, correspondence, DOJ CVSD reports such as site visits and DOJ CVSD Request for Application (RFA). 47

53 2. Commingling of Funds Federal agencies shall not require physical segregations of cash deposits or the establishment of any eligibility requirements for funds which are provided to a grantee. However, the accounting system of all grantees must ensure that VOCA funds are not commingled with funds from any other source. Funds specifically budgeted and/or received for one grant project may not be used to support another. Revenues and expenditures for each grant should be separately identified and tracked within the grantee s accounting system or records. Where a grantee s accounting system cannot comply with this requirement, the grantee shall establish a system to provide adequate fund accountability for each grant awarded. Funds should not be commingled on a program-by-program or project-by-project basis. Individual accounts or cost centers should be established to control the funds for each grant. Proof of this will be requested as part of a site visit or desk audit. 3. Grantee Accounting Responsibilities a. Audit Requirements Grantees must meet the necessary audit requirements contained in the OJP Financial Guide: Nonfederal entities that expend $500,000 or more in federal funds (from all sources including pass-through sub-awards) in the organization fiscal year shall have a single organization-wide audit conducted in accordance with the provisions of OMB Circular A-133 (codified at 28 CFR Parts 66 and 70). Audits are due no later than nine (9) months after the close of each fiscal year during the term of the award. Non-federal entities that expend less than $500,000 a year in federal awards are exempt from federal audit requirements for that year. Audit costs for audits not required or performed in accordance with OMB Circular A-133 are unallowable. If a grantee did not expend $500,000 or more federal funds in its fiscal year, but contracted with a certified public accountant to perform an audit, these costs may not be charged to the grant. Grantees are not required to send copies of audits to DOJ CVSD unless they are required to conduct single organization-wide audits. b. Reporting of Irregularities Grantees are responsible for promptly notifying DOJ CVSD of any illegal acts or irregularities and of proposed and actual actions, if any. Illegal acts and irregularities include conflicts of interest, falsification of records or reports, and misappropriation of funds or other assets. 48

54 B. Program Income Any revenue generated by VOCA grant activities is considered program income. Any earned program income requires advance approval by DOJ CVSD and by the Office of the Comptroller for the U.S. Justice Department, Office of Justice Programs. DOJ CVSD discourages applications that include any component that generates program income. C. Property and Equipment Inventory information on equipment purchased with VOCA funds must be kept in the grantees VOCA file. A control system shall be in effect to ensure adequate safeguards to prevent loss, damage or theft to nonexpendable personal equipment. Any loss, damage or theft of nonexpendable personal equipment shall be investigated, fully documented and made part of the grant file. DOJ CVSD uses the federal definition of equipment: Tangible nonexpendable personal property having a useful life of more than one year and an acquisition cost of $5,000 or more per unit. At a minimum, property records must be maintained with the following: a description of the property and a serial number or other identifying number; identification of title holder; the acquisition date; the cost and the percentage of VOCA funds supporting the purchase; the location, use, and condition of the property; and any disposition data, including the date of disposal and sale price. Federal policies and procedures on the acquisition and disbursement of the equipment, in the event the grant recipient no longer receives a VOCA grant, will be applied. Please refer to Appendix B for more information. Positive efforts should be made to utilize goods and services from small business and minority-owned business sources. Such efforts should allow these sources the maximum feasible opportunity to compete. Such positive efforts may include small business and minority set-asides, the break-out of work that could be readily handled by small business or minority firms, and should include the aggressive recruitment of small business and minority firms for bidder s lists. D. Procurement Standards Federal requirements state that all procurement transactions shall be conducted in a manner to provide, to the maximum extent practical, open and free competition. These requirements apply to all procurements, including, but not limited to, procurements for goods, services, and equipment. Grantees shall follow their own established procurement procedures and regulations, provided they minimally adhere to applicable federal and state guidelines and standards. If a grantee s established procurement procedures are less competitive than the federal requirements, the grantee must adhere to the following more competitive procurement requirements: For small procurements of $5,000 or less, grantees may solicit goods or services in any manner deemed practical or convenient. A procurement may not be artificially divided or fragmented so as to constitute a small procurement. For procurements exceeding $5,000 but not exceeding $100,000, grantees must solicit quotes or bids from at least three sources. 49

55 For procurements over $100,000, grantees must formally advertise the proposed procurement through an Invitation for Bids (IFB) or a Request for Proposals (RFP) process. Grantees must follow the threshold limitations established in their own procurement procedures if their internal procedures are more restrictive than the federal threshold. Grantees must submit all IFBs and RFPs over $100,000 that involve the use of federal or matching funds to DOJ CVSD for review and approval prior to their issuance. Interagency agreements between units of government are excluded from this provision. Grantees must have written procurement procedures and these procedures must be made available to DOJ CVSD for review during monitoring to assure adherence to applicable federal guidelines. Sole Source Procurement In rare and unusual circumstances it may be necessary to waive the competitive bid process and utilize a sole source, noncompetitive, procurement. Grantees may make the determination that competition is not feasible if one of the following circumstances exists: 1. The item or service is available only from a single source. 2. A public exigency or emergency will not permit a delay resulting from a competitive solicitation; or if it can be shown unequivocally that desired time frames for delivery must be met or the entire program will suffer as a direct result of the delay. 3. After solicitation of a number of sources, competition is considered inadequate. If sole source procurement is pursued, documentation reflecting actions taken and the position of the grantee is required. A justification statement for all sole source contracting should include: 1. A brief description of the program, the amount to be designated for the sole source procurement, and the purpose of the contract. 2. Explanation of why it is necessary to contract in a noncompetitive manner by providing supporting information as identified below in the applicable section(s): a. If the item or service is available only from one source, describe the contractor s expertise related to the current program (knowledge of program management, responsiveness, knowledge of the program, experience of contractor personnel), the uniqueness of items to be procured from the contractor (these services or items are only available from a single contractor), and any additional information that would support the case. b. If a public exigency or emergency will not permit a delay resulting from a competitive solicitation, describe when the contractual coverage is required, the impact on the program if deadline dates are not met, how long it would take an 50

56 alternate contractor to reach the same level of competence, and any additional information that would support the case. c. If competition is determined inadequate after solicitation of a number of sources, describe the market survey, or similar effort, used to determine competition availability, and any additional information that would support the case. 3. A declaration that this action is in the best interest of the agency. For all sole source procurements in excess of $100,000, grantees must submit a justification statement for review and approval from DOJ CVSD prior to procurement. Interagency agreements between units of government are excluded from this provision. 51

57 SECTION 7 GRANTEE MONITORING I. OVERVIEW DOJ CVSD is responsible for the monitoring of grant recipient awards to ensure compliance with applicable federal and state guidelines. DOJ CVSD will provide program and fiscal monitoring and evaluation of grants between DOJ CVSD and grant recipients. Monitoring is conducted to determine if the grant recipient is adequately providing services outlined in their grant application and in accordance with the DOJ CVSD Grant Agreement, established program policies and procedures and this Handbook. Accomplishing these grant recipient monitoring objectives is achieved through a variety of monitoring techniques, including grant monitors review of reports, a telephone interview and on-site visit to the grant recipient agency, or a desk review. II. SITE VISITS A site visit may be prompted by: concerns within the agency, either as reported to the grant monitor by the agency or other parties; routine time for a visit (36 months since last visit), with no apparent concerns; or a request for a site visit by the grantee. Prior to the scheduled, inperson visit to the location of a grantee, a structured telephone interview will be held with the director or project manager. The telephone interview and in-person site visit will include a review of the following: Program administration; Financial reporting and accounting; Systems and controls; Program service delivery; and Compliance with federal and state regulations/guidelines as appropriate. Each grantee is responsible for keeping records that fully disclose the amount and disposition of the proceeds of the grant. This includes financial documentation for disbursements, daily time/attendance records specifying time devoted to VOCA allowable victim services, client files, the portion of the grant supplied by other sources of revenue, job descriptions, contracts for services, receipts and other records which facilitate an effective site visit or desk review. Records shall also be kept pertaining to the total cost of the services for which the grant is awarded, the amount and disposition of the proceeds of the grant, and the amount and disposition of that portion of total costs provided from nonfederal sources. The procedures developed by each grant must provide for the accurate and timely recording of the receipt of funds, expenditures and unexpended balances. Adequate documentation of each transaction shall be maintained to permit the determination, through a site visit or desk review, of the accuracy of the records and whether expenditures charged to grant funds are allowable. All records relating to the VOCA grant must be retained and available for inspection for a period of six (6) years following the end of the federal grant period (the grant end date). Please refer to Appendix F for a copy of the grant monitoring form used by your DOJ CVSD grant monitor for both the telephone and in-person portions of your program review. 52

58 III. FAILURE TO COMPLY WITH THE TERMS AND CONDITIONS OF A VOCA GRANT If a grantee significantly fails to comply with the terms and conditions of a grant agreement, including civil rights requirements, whether stated in a federal statute, regulation, assurance application or notice of award, DOJ CVSD may take one or more of the following actions, as appropriate per the circumstance: Temporarily withhold cash payments pending correction of the deficiency by the grantee; Disallow (that is, deny both use of funds and any applicable matching credit) for all or part of the cost of the activity or action not in compliance; Completely or partially suspend or terminate the current grant; Withhold further grants for the agency or program; and Take other remedies that may be legally available. DOJ CVSD may, after reasonable notice, terminate or suspend funding for a grantee organization that fails to conform to the requirements or objectives of the Victims of Crime Act, and/or that fails to comply substantially with the DOJ CVSD grant agreement. In that event, the grantee shall be entitled to receive equitable compensation for satisfactory, authorized services completed as of the termination date. If the grantee fails to fulfill its VOCA grant obligation in a timely manner, DOJ CVSD shall have the right to immediately terminate or suspend the grant and withhold payments in excess of fair compensation for completed services. Notwithstanding the above, the grantee shall not be relieved of liability to DOJ CVSD for damages sustained by virtue of any breach of the grant agreement by the grantee. While termination of funding will not be exercised without prior written notice to the grantee, any consideration of future grant requests may be influenced by the gravity and extent of the irregularities causing the termination as determined by DOJ CVSD. Failure by a grantee to comply with the terms of the grant agreement or of the requirement described in this Handbook may be considered grounds for termination of grantee funding. In the event of a formal allegation or a finding of fraud, waste and/or abuse of VOCA funds, DOJ CVSD must be immediately notified. DOJ CVSD will then notify the Office for Victims of Crime. Suspension or termination of funds may be lifted when the grant recipient organization has demonstrated substantial compliance. Termination or suspension action will only be taken as a last resort. The staff of DOJ CVSD is committed to assisting grantees to realize the success of any given grant and will utilize all reasonable means to resolve problems or address potentially critical issues. Whenever possible, and in the best interest of victims, assistance will be provided to grantee agencies to prevent such actions. 53

59 APPENDICES Grantees using this VOCA Handbook are using the CVSD E-Grant system. All forms, excluding the MOU suggested format, can be found in the CVSD E-Grants.

60 STATISTICAL REPORTING INSTRUCTIONS AND SERVICE DELIVERY DEFINITIONS Appendix A Top Section: Type of Victimization This section should include figures that are unduplicated. Please see the examples provided on reporting unduplicated data on pages of this Handbook. Bottom Section: Service Delivery Report only the VOCA-funded services provided by this grant. Below is a description of the services. 1) Crisis Counseling. Refers to in-person crisis intervention, emotional support, and guidance and counseling on an individual basis provided by counselors, mental health professionals or peers. Such counseling may occur: a) at the scene of a crime; b) immediately after a crime; c) at the first, in-person contact between a counselor and victim (this would include meeting a victim in an emergency room, police station, district attorney s office, etc.); d) during in-person contact for the duration of the crisis experience; or e) in the case of survivors of homicide victims of DUI/DWI, counseling may occur months after the victimization. 2) Follow-up Contact. Refers to individual emotional support, empathetic listening, and guidance for other than crisis reactions after the victimization. 3) Therapy. Refers to intensive professional psychological/psychiatric treatment for individuals, couples, and family members. This includes the evaluation of mental health needs, as well as the actual delivery of psychotherapy. 4) Group Treatment/Support. Refers to the coordination and provision of supportive group activities. This category includes self-help, peer, social support, drop-in groups, and community crisis intervention in a group setting. 5) Shelter/Safe House. Refers to offering short-term and long-term housing and related support services to victims and members of their family following victimization. 6) Information and Referral (in-person). Refers to in-person contacts with the victim and identifying services offered and support available by the subgrants project and other community agencies. 7) Criminal Justice Support/Advocacy. Refers to law enforcement and prosecution investigation support, assistance during investigation, and explanation of procedures, etc. Included in this definition are: courtrelated support, i.e., court orientation, court escort, case appearance notification, case status and disposition information, victim impact reports, assistance with restitution, witness fees, intimidation or protection services, transportation, child care, property return, etc.; and post-sentencing services following the disposition of a criminal court proceeding, including offender release notification at the probation, parole, and pardon stages of the criminal justice system, etc. 8) Emergency Financial Assistance. Refers to locating emergency loans and petty cash; assistance in filing for losses covered by public and private insurance programs including worker s compensation, unemployment benefits, welfare, and Medicare; and payment for taxis, food, emergency shelter, and clothing. 9) Emergency Legal Advocacy. Refers to filing temporary restraining orders, injunctions and other protective orders, elder abuse petitions, and child abuse petitions but does not include criminal prosecution or the employment of private attorneys for non-emergency purposes. 10) Assistance in Filing Compensation Claims. Includes making victims aware of the availability of crime victim compensation and assisting the victim in completing the required forms and in gathering the needed documentation. It may also include follow-up contact with the victim compensation agency on behalf of the victim. 11) Personal Advocacy. Refers to assisting victims in securing rights and services from other agencies; intervention with employers, creditors and others on behalf of the victim; and other general information on rights and remedies available to the victim. 12) Information and Referral (telephone). Refers to telephone contacts with the victim and identifying services offered and support available by subgrant projects and other community agencies. 13) Crisis Hotline. Typically refers to the operation of a 24-hour telephone service, 7 days a week, which provides counseling, and information and referral to victims and survivors. 14) Other. Identify any services not listed that are offered to crime victims by the subgrant program

61 Appendix B PROPERTY AND EQUIPMENT REQUIREMENTS (From OJP Financial Guide: The term property in this appendix is used similarly with the term capital outlay described in the Handbook.) Acquisition of Property and Equipment. When purchasing and managing property paid for by Federal funds, we expect you to use good judgment. If you use your award funds to purchase new property when suitable property is already available within your organization, this use will be considered an unnecessary expenditure. Screening. Careful screening should take place before purchasing property/equipment to ensure that it is needed. If you do not establish and maintain an effective property management system, your project costs associated with the acquisition of the property may be disallowed. 1. Take stock of the equipment that you already have and see if it meets identified needs. 2. Consider establishing a screening committee to make decisions about purchases. 3. You may utilize other effective management techniques as a basis for determining that the property/equipment is needed. 4. During grantee monitoring, DOJ CVSD grant monitors will ensure a screening process takes place and that you have an effective system for property management. Loss, Damage, or Theft of Equipment. Grantees are responsible for replacing or repairing property which is willfully or negligently lost, stolen, damaged, or destroyed. You must investigate and fully document any loss, damage, or theft of the property and make the documentation part of the official grant records. Equipment Acquired with Victims of Crime Act (VOCA) Assistance Funds. If you have acquired equipment using funds from the Office for Victims of Crime (OVC), then you are legally required to ensure that the equipment is used for criminal justice purposes. The following standards and procedures govern ownership, use, management, and disposition of this type of equipment: 1. Title. Title to equipment acquired under an award or sub-award will vest in your organization with the right of immediate or future legal ownership upon acquisition, subject to the obligations and conditions set forth in Title 2 Code of Federal Regulations (CFR) Use. Grantees should use equipment in accordance with the following requirements: a. Equipment must be used by the grantee in the program or project for which it was acquired as long as needed, whether or not the program or project continues to be supported by federal funds. When no longer needed for the original program or project, the equipment may be used in other activities currently or previously supported by a federal agency. b. Grantee must also make equipment available for use on other projects or programs currently or previously supported by the federal government, provided the use does not interfere with the work on the projects or programs for which it was originally acquired. First preference for other use should be given to other programs or projects supported by the awarding agency. User fees should be considered and treated as program income to the project, if appropriate.

62 c. Aside from program income grantee should not use equipment acquired with these funds to provide services for a fee or to compete unfairly with private companies that provide equivalent services, unless specifically permitted, or contemplated by federal law. d. When acquiring replacement equipment, grantee may use the equipment to be replaced as a trade-in or may sell the equipment and use the proceeds to offset the cost of the replacement equipment, subject to the written approval of the awarding agency. 3. Management. The procedures grantees must use for maintaining equipment acquired in whole or in part with grant funds (including replacement) must, at a minimum, meet the following requirements: a. Grantees must maintain property records which include all of the following information: 1. Description of the property; 2. Serial number or other identification number; 3. Source of the property; 4. Identification of the title holder; 5. Acquisition date; 6. Cost of the property; 7. Percentage of federal participation in the cost of the property; 8. Location of property; 9. Use and condition of the property; and 10. Disposition data, including the date of disposal and sale price. b. Grantees must take a physical inventory of the property and reconcile the results with the property records at least once every two years. c. Loss, damage, or theft 1. Grantees must have a control system in place with adequate safeguards to prevent these occurrences. 2. Grantees must promptly and properly investigate any loss, damage, or theft. 3. Grantees must establish and use adequate maintenance procedures to keep the property in good condition. 4. If authorized or required to sell the property, grantees must establish proper sales procedures to ensure the highest possible return, 4. Disposition a. Grantees must dispose of the equipment when original or replacement equipment acquired under the award or sub-award is not longer needed for the original project or program. Grantees are also required to dispose of equipment acquired under the award when the equipment will be used for other activities currently or previously supported by a federal agency. Grantees must adhere to the following rules in equipment disposition: 1. If the item to be disposed of has a current per-unit fair market value of less than $5,000, grantee may retain, sell, or otherwise dispose of it with no further obligation to the awarding agency. 2. If the item has a current per-unit fair market value of $5,000 or more, grantee may retain or sell it, but the awarding agency will have a right to a specific dollar amount. Calculate this amount by multiplying the current market value or proceeds from the item sale by the awarding agency s share of the equipment. The seller is also eligible for sale costs. 3. In cases where a grantee fails to take appropriate disposition actions, the awarding agency may direct the grantee to take other disposition actions.

63 Appendix C QUICK REFERENCE CHART: VOCA ALLOWABLE AND UNALLOWABLE COSTS Type of Service, Activity or Cost Allowable Not Allowable Administration time (to complete VOCA documentation) Audits (receiving less than $500,000 in federal funds) Building purchase Capital improvements and construction (limited) Cell phones for staff and volunteers Cell phones for victims Computers Conference costs for individual crime victims Contractors for professional services (limited) Coordination efforts (i.e., task forces) Counseling, group treatment, and therapy Equipment and furniture Forensic examinations for sexual assault victims Fundraising activities Heat and electricity (for program) Immediate health and safety needs (i.e., emergency services) Indirect costs Investment of VOCA grant funds Leasing vehicles Liability insurance for buildings, property Liability insurance for staff Lobbying and administrative advocacy Membership fees (limited) for victim services & issues (for agency, not individuals) Mortgage payments Most medical costs Needs assessments, surveys, studies, research and evaluations Non-emergency legal representation (i.e., divorces) Operating costs (providing direct services to victims) Pager for staff and volunteers Perpetrator rehabilitation and counseling Presentations: crime prevention/community education Presentations: to public to help identify crime victims and increase access to services Prevention activities Property insurance on equipment (pro-rated) Prosecution activities Reimbursements to crime victims property losses Rent ( for victim services program) Restorative justice/victim-offender meetings (restricted) Repair or replacement of essential items Salaries and benefits of victim services staff Security systems for program/agency Telephone service Trainings for individuals not providing direct services Trainings for staff, training materials Transportation expenses Vehicle purchase Victim relocation expenses Volunteer coordinator position Water and sewer Witness activities (for those who are not crime victims)

64 APPENDI D Minimally Recommended Elements for an Independent Contractor Agreement CVSD recommends that the following categories be included in any Subcontractor Agreements included in an E-grants application. In addition, any grant award policies and requirements that are applicable to the contractor and, as appropriate, the cost principles to be used in determining allowable costs should be included in the Agreement. Sample templates of Personal/Trade Services and Goods Agreements, approved by DOJ, are available at the following website as a reference to provide guidance to the development of Agreement language: PARTIES Indicate the official names and addresses of the parties to the Agreement, usually this is the Grantee who is awarding/funding the subcontract (generally referred to as the Agency) and the recipient of the subcontracted funds (generally referred to as the Contractor). TERM Indicate the start date (generally, the date indicated in the Agreement or the date the Agreement is executed by both parties, whichever is later) and the end date of the Agreement (generally, the date indicated in the Agreement, unless the Agreement is suspended or terminated, pursuant to a Termination Clause prior to the termination date). SCOPE OF WORK AND DELIVERABLES Defines the services for which the awarding Agency is engaging the Contractor, the results to be delivered by the Contractor, and the schedule for the delivery of services and results. COMPENSATION Defines the maximum compensation for the Scope of Work and Deliverables, defines the payment method and schedule of payment(s). Compensation can be time and materials at a specific rate, it may be a fixed fee payable in installments, or some other negotiated payment system. This section should define the invoicing and reporting schedule and requirements for the Contractor. This section should also define the when the Agency will make payment to the Contractor following the submission of invoices and/or reports. INDEPENDENT CONTRACTOR RELATIONSHIP This section should state that the Agreement does not create an employer/employee relationship between the Agency and the Contractor; it should state that the Contractor is not entitled to any Agency benefits; and it should state that the Agency is not liable for taxes, Workers Compensation, Unemployment Insurance, FICA, Social Security, withholding tax, etc. for or on behalf of the Contractor. You can refer to Oregon s Independent Contractor Laws at the following website: definition.shtml. REPREMENTATIONS AND WARRANTIES State that the Contractor has the authority to enter in the Agreement; that the Contractor will perform services in a timely, professional and workmanlike manner; that the Contractor shall maintain any required license(s). INDEMNIFICATION State that the Contractor shall defend, hold harmless and indemnify the Agency against all claims resulting from Contractor acts or omissions.

65 CONFIDENTIALITY Include and hold the Contractor responsible for adhering to your Agency confidentiality policy. TERMINATION, DAMAGES AND REMEDIES State that the Agreement can be terminated by mutual consent with a specific number of days written notice and that the Agency can terminate at its own discretion for specified reasons, or no reason, either immediately or within a specific number of days written notice. Specify, should the Agreement be terminated, what materials, if any, should be provided from Contractor to Agency and how termination payment will be handled. INSURANCE Specify what insurances the Contractor must carry and the levels of coverage for some or all of the following types of insurance: Workers Compensation, Commercial General Liability, Professional Liability, Auto Liability. Consider requiring the Contractor to provide Certificate(s) of Insurance and including the Agency as an Additional Insured. AMENDMENTS State that the Agreement is the entire Agreement and that the Agreement cannot be amended, changed, or supplemented in any way except by written Amendment signed by both parties. SIGNATURES OF AUTHORIZED REPRESENTATIVES State the signer is authorized to act on behalf of Contractor; that Contractor is, to the best of the signer s knowledge, not in violation of any Oregon Tax Laws; and that Contractor is bound by and will comply with all requirements, terms and conditions contained in the Agreement. By: Title: Date: By: Title: Date:

66 APPENDI E SAMPLE FORMAT AND CONTENT MEMORANDUM OF UNDERSTANDING All italicized sentences are considered instructions and should be deleted prior to the submission of the final MOU. This Memorandum of Understanding (MOU) is entered into by and between: Provide the agency name and a brief description of each agency i.e. non-profit Domestic Violence non-shelter provider. A. Purpose. State the purpose of the MOU. Include statements that explain how the sub-contracting and/or the collaborative relationship enhances or benefits the Applicant s program; B. Roles and Responsibilities. Clearly describe and delineate the agreed upon roles and responsibilities each organization or agency will be providing to ensure project success. The roles and responsibilities should align with project goals, objectives and target outputs. This may be time commitment, in-kind contributions or grant funds and could include but is not limited to the following: training, workspace, volunteer hours, Agency A agrees to: Responsibility/Activity Responsible Staff Agency B agrees to: Responsibility/Activity Responsible Staff C. Reporting Requirements. Describe who will be responsible for collecting, collating and submitting data as per the project target outputs and outcomes. D. Funding. Clearly describe any grant funds, the amount and category (personnel, office supplies, contracted services, etc.) that will be provided to the non lead agency(s). If this question is not applicable, please respond NA to this question. E. Timeframe. Clearly state the time period that this MOU will be in effect. This MOU will commence on and will dissolve at the end of the VOCA grant funding period on.

67 F. Confidentiality. (REQUIRED) 3 In order to ensure the safety of clients, all parties to the memorandum of understanding agree to adhere to the confidentiality expectations as outlined in the VOCA Grant Agreement. The designated lead agency accepts full responsibility for the performance of the collaborative organizations/agencies. (REQUIRED) This Memorandum of Understanding is the complete agreement between and and may be amended only by written agreement signed by each of the parties involved. The MOU must be signed by all partners. Signatories must be officially authorized to sign on behalf of the agency and include title and agency name. AGENCY A Authorized Official: Signature Printed Name and Title Address: Telephone(s): Address: AGENCY B Authorized Official: Signature Printed Name and Title Address: Telephone(s): Address: This form is included for your reference and is not intended for use 3 All items marked required must be included in the memorandum of understanding.

68 APPENDI F OREGON DEPARTMENT OF JUSTICE Crime Victims Services Division Phone Review & Site Visit Monitoring Instrument Agency/Program Name: Telephone Review Date: In Person Visit Date: Grant Monitor(s): Office Hours: (open to the public/open for appointments) Physical Address: (if not on current application, please indicate here) Program Contact: Fiscal Contact: Site Visit Schedule: (Please contact the appropriate Fiscal Officer so we may meet during this visit.) VOCA Grant: Grant Number Grant Type Grant Amount Match Amount Time Period Position Funded FTE Name of Staff Changes in Job VAWA Grant: Grant Number Grant Type Grant Amount Match Amount Time Period Position Funded FTE Name of Staff Changes in Job ODSVS Grant: Grant Number Grant Type Grant Amount Match Amount Time Period Position Funded FTE Name of Staff Changes in Job

69 Other (Insert) Grant: Grant Number Grant Type Grant Amount Match Amount Time Period Position Funded FTE Name of Staff Changes in Job Comments: A. HUMAN RESOURCES & COMMUNITY PARTNERSHIPS 1. Board of Directors (Non Profits Only): Attribute Yes No Comments Action 1. Represent Community 2. Appropriate Size 3. All Positions Filled 4. Conflict of Interest Policy 5. Active in Program 6. Productive Relationship with Director/Coordinator 7. Regularly Scheduled Meetings 8. Meeting Minutes (provide minutes from 2 meetings) 9. Quorum at All Meetings 10. Approve Budget 11. Authorize Expenditures 12. Notify CVSD if there is a Change in Exe. Director. 13. Training 2. Personnel Attribute Yes No Comments Action 1. Culturally Representative 2. Orientation Training 3. Ongoing Staff Development 4. Grant-funded staff have read and understand grant materials Informed on goals/object/pm? Tracking for reporting? Understand fund specific requirements 5. Staff Change Are all grant funded positions currently filled Have there been gaps in any grant funded positions during grant period. 6. High Turnover Rate

70 3. Volunteers: Attribute Yes No Comments Action 1. Recruitment 2. Basic Training/Orientation 3. On-Going Training 4. Supervision If VAWA funds support a Vol. Coordinator, volunteer statistics must be reported on Muskie. 5. Culturally Representative 6. Workload Reasonable 7. High Turnover Rate 8. Interns 4. Community Partnerships: Attribute Yes No Comments Action 1. Law Enforcement 2. Social Service Agencies 3. Multi-Disciplinary Team 4. Elder Abuse Task Force 5. Family Violence/DV Council or DART/DVERT 6. Sexual Assault Task Force/SART 7. Underserved, Marginalized, and/or Oppressed Communities/Groups Outreach 8. Tribal Nations formal agreements vs informal collaborations funds given to Tribal nations vice versa clear understanding of the relationship and responsibilities. 9. District Attorney based VAP 10. CVRW & DV/SA/CAA Month Participation B. AGENCY INFRASTRUCTURE 1. Recent documents reviewed by CVSD Staff: Each grantee is required to maintain statutorily required civil rights statistics on victims services by race, national origin, sex, age and disability. Nonpersonal identifying, aggregate only. These civil rights stats must be kept on file with other VAWA/VOCA grant documentation and must correspond with each grant period. Document Date Comment Action Organizational Chart Staff Roster Annual Budget Annual Revenue Summary *990 *Civil Rights Appendices

71 2. Planning, Policy & Procedures (View All) First three are really best practice. Having a separate policy and volunteer manual for VAP is also a best practice Attribute Yes No Comments Action 1. Mission Statement 2. Strategic Plan 3. Cultural Competency Plan/Training 4. Agency Policy & Procedure Manual 5. Volunteers Policy & Procedure Manual 6. Grievance Policy (Staff & Clients) 7. Confidentiality/Release of Information Policies 8. CVCP Procedures/Policies 9. Criminal History Verification Policy (Grant agreement requires a policy be in place) a. What is the process for staff versus volunteers 10. *Policies of Equal Opportunity Employer posted at all worksites (i.e. Non-Discrimination, Drug-Free Workplace) 11. Agency Brochure 3. Contracts & Memorandum of Understanding (MOU) This only refers to subcontracts and MOU s using CVSD grant funds. Meet or at minimum have a phone conversation with MOU partners (coordinated project activities w/out grant funds) Subgrantee must assure that subcontractor is held to same federal requirements as subgrantee (consultant fees, perdiem rates, etc.). The subgrantee is responsible for monitoring the subcontractor and determining that all fiscal and programmatic responsibilities are fulfilled. A. Memorandum of Understanding (MOU) Not Applicable ODSVS VAWA VOCA CAMI Attribute Yes No Comments Action 1. Signed MOU(s) on file 2. Does the grantee verify, through monitoring or other means, that MOU deliverables are being provided as stated in the MOU? B. Sub-Contracts Not Applicable ODSVS VAWA VOCA CAMI Attribute Yes No Comments Action 1. Signed Subcontract(s) on file 2. Subcontractor can describe program goals/objectives 3. Subcontractor can describe grantee and subcontractor roles and responsibilities.

72 4. Are the subcontractors performing the work described in the MOU and the subcontract? 5. Does the grantee verify, through monitoring or other means, that contract deliverables are being provided as stated in the subcontract? 6. Does the grantee have an established procurement procedure? a. Federal guidelines apply for VAWA/ VOCA grants. If no other procedures are established, federal guidelines apply. 7. Grantee ensures that subcontract payments are not made unless receipt of goods or services is verified. Expenditures align with subcontract agreement and budget. 8. Grantee has documentation (invoice) supporting subcontractor request for payment. 4. Fiscal Management (General & Grant-Specific): Attribute Yes No Comments Action 1. Liability Insurance Coverage 2. Formal Accounting System 3. Understanding of Allowable Expenses for each grant fund. 4. Expenditures & obligations coincide with grant & budget 5. Program/Budget Amendment (redirect) & Justification Process b. CVSD Amendment Policy c. Amendments in E-Grants 6. Records Separate from other funding sources 7. Records Safe/Secure 8. Separation of Duties/checks and Balances in Place Are responsibilities for supervision & time keeping, personnel, payroll processing, disbursements, and general ledger functions assigned to provide division of duties Signature Checks Policy 10. Retention of Records 11. *Audit Required? (Expended $500k or more in Federal Funds in the Past Year?) a. Copy of Audit Report sent to CVSD (provide website/electronic copy if possible) 13. *Supplanting Supplementing existing funds and not replacing. This pertinent to VAWA/VOCA

73 5. Equipment: Equipment means tangible non-expendable personal property including exempt property charged directly to the award having a useful life of more than one year and an acquisition cost of $5,000 or more per unit (2 CFR Part 215). Attribute Yes No Comments. Action 1. Has the Agency purchased or has plans to purchase equipment under this grant. 2. Equipment purchases are supported with appropriate documentation (receipts)? Receipts match the ledger View actual equipment item 3. Inventory Kept a. USDOJ Financial guide details this. 4. Equipment used for Victim Services only 5. Disposition of Equipment Federal requirement: 3 yrs for records for equipment once the item has been replaced/transferred, etc. NA ODSVS VAWA VOCA CAMI 6. Other: Attribute Yes No Comments Action 1. *During the last 3 years, has a Federal or State Court or a Federal or State Administrative agency issued a finding of discrimination against the subgrantee after a due process hearing on the grounds of race, color, national origin, age, sex, religion or disability? 2. *If applicable, verify that the grantee submitted an EEOP certification form or an EEOP to Office for Civil Rights, Office of Justice Programs, US DOJ, Washington D.C (Exhibit D of grant agreement). 3. Does the grantee need any civil rights training or technical assistance regarding its duties to comply with the applicable civil rights laws? 4. Lawsuits Pending? C. COMPLIANCE (Grant Files & Reporting): View all Grant Files. How has using E-grants changed the way grant information is being organized? Attribute Yes No Comments Action 1. Separated Grants on File 2. Cover Sheet 3. Grant Agreement & Amendments 4. Current Budget & Narrative 5. Current Project Description 6. Current Goals & Objectives 7. Copies of Contracts (as applicable) 8. Copies of MOUs (as applicable)

74 2. Financial Reporting: (View All) This section will be completed during the site visit. Attribute Yes No Comments Action 1. Expenditures Documented a. Do expenditures require an approval by a supervisor to ensure costs are authorized, allowable and consistent w/the grant agreement? b.all costs are allowable c. All costs are expended in accordance with the approved budget. d.grantee is not obligating grant funds before the beginning, or after the end of the grant period. e. Spending is on track. 2. Receipts Labeled and Filed Receipts align with ledger and are filed with QFR 3. Mileage recorded (Grant-funded) 4. Travel Guidelines followed a. Reimbursement for travel does not include meals provided by conference/training. b.proof of attendance available 5. Timesheets/Salary Records a. Positions partially funded by the grant clearly and accurately reflect the allocations and align with the approved budget. b.are records maintained showing hours worked for each program and approved. c. Are completed payroll charges reviewed before disbursements are made. d.are confidential payroll records and reports adequately safeguarded. 6. Documentation of Volunteer Hours used as match a. View the tracking system used to report volunteers hours for the previous quarter. b.volunteer time used for in-kind match is appropriately documented and not used for other match. 7. Volunteer Benefit Rate Reasonable a. The rate does not exceed the $$ per hour rate for staff with the same responsibilities. 8. Source & amount of match verified for each period a. View the tracking system for match including volunteers 9. Sufficient documentation of determining match (in-kind, cash) 10. Match is not included as contribution for other federal funds 11. Financial reports reconciled with project budget & prior grant reports (Non E-Grant question) a. Revenue/Expenditure reports align w/project budget and the financial report 12. Concerns with past reports

75 3. Statistical Reporting: (View All) Attribute Yes No Comments Action 1. Understand non-duplicated victims 2. Understand service definitions 3. Understand volunteer hour reporting 4. Statistical record-keeping 5. Documentation kept with each report 6. *Civil Rights Information View tracking of this information 7. Concerns with past reports 4. Narrative Reporting: Attribute Yes No Comments Action 1. Understand Outputs & Outcomes 2. Concerns with past reports 5. Common Outcome Reporting: Attribute Yes No Comments Action 1. Correct outcomes being tracked 2. Correct 5-point scale being used 3. Procedure for distribution/return 4. Procedure for feedback 5. Concern with past reports D. Materials to Bring to Visit: Identify type of materials and quantity. VINES CVCP Crime Victim Rights Materials ACP Site Visit Notes (for CVSD use only) Staff met with: Program Strengths: Program weaknesses, problems, areas of concern or areas of non-compliance: Corrective action needed or taken to address above issues: Follow-up needed: See site visit summary: DM #

76 CAMI Addendum: A. MDT STRUCTURE: MDT MEMBERSHIP Attribute Yes No Comments Action 1. All mandated members on team? DA LEA DHS Mental Health Health Dept School Juvenile Dept 2. Conflict resolution or grievance policy 3. Productive Relationship with Chair/Coordinator 4. County has Child Abuse DMP? 5. Approve Budget & Intervention Plan 6. Authorize Expenditures 7. Notify CVSD: Change in Chair or Coordinator positions 8. Training request procedure or guidelines followed 9. Is CAIC prioritized in MDT budget? To what extent?

77 B. MDT STRUCTURE: MDT Meetings and Procedures Attribute Yes No Comments Action 1. Regularly Scheduled Meetings 2. Maintain Mtg Attendance Records? 3. Intervention Plan 4. Cultural Competency Plan/Training 5. MDT Protocols Are In Place? Investigation Karly s Law DEC Fatality Review Compliance 6. Are Protocols up to date and in line with current statute? (eg Karly s Law) 7. Assessment/Intervention Referral Procedures in Place? (ie 1 st responders and MDT members know what to do when new cases arise) 8. Role Definition Do MDT members know their role on MDT and Fatality Team, and function of the process? 9. New MDT member orientation 10. Confidentiality Process in Place? 11. Release of Information Policies / Information Sharing Policies in Place? DA/CA VAP Addendum: A. Reporting/Policy: Attribute Yes No Comments Action 1. Review VRRF form Ensure the form matches the progress report questions 2. Policy/Procedures for CFA statutory requirements ( : Program Content Core Services) 3. Concern with past reports B. Post Conviction Program Reporting: Attribute Yes No Comments Action 1. Submit monthly VRF forms for all person crime convictions 2. Provide PCP forms to all victims at time of judgment 3. Procedure for submitting forms (Are the forms complete, legible, relevant.)

78 APPENDI G VOCA GRANT RECIPIENT RESOURCE PAGE RESOURCE PURPOSE WEB-ADDRESS Department of Justice, Crime Victims Services Division Crime Victim s Compensation Program Oregon Attorney General s Sexual Assault Task Force Crime Victim Assistance Network National Coalition Against Domestic Violence National Criminal Justice Reference Service National Center for Victims of Crime National Crime Victim Law Institute National Organization for Victim Assistance Reporting forms and requirements, Grant Update Packets, Upcoming Meetings and Events The CVCP provides compensation for the financial losses of a victim and the victim s family as a result of violent crimes. To provide leadership in Oregon for the efforts of improving the prevention of and response to sexual assault. CVAN advocates for the Rights of Victims and to Promote Victims Services. Includes State Victim Assistance Academy (SVAA) The NCADV provides national level organization of communities and individuals working to end the violence in our lives. NCJRS is a federally funded resource offering justice and substance abuse information to support research, policy, and program development worldwide. NCJRS offers a range of services and resources for victim assistance. The NCVC is the nation's leading resource and advocacy organization for crime victims and those who serve them. The NCVLI promotes and supports victims' rights and legal technical assistance to victims' attorneys and others serving victims. NOVA s promotes the rights and services for victims of crime It provides national advocacy, direct services to victims, assistance to professional colleagues

79 RESOURCE PURPOSE WEB-ADDRESS Office for Victims of Crime Oregon Coalition Against Domestic and Sexual Violence Bureau of Labor and Industries Technical Assistance The Nonprofit Association of Oregon Foundation Center Bureau of Labor and Industry Civil Rights Division Oregon Crime Victim Rights Compliance Oregon Human Trafficking Task Force (OHTTF) OVC was established by the 1984 Victims of Crime Act (VOCA) to oversee diverse programs that benefit victims of crime. OVC provides substantial funding to state victim assistance and compensation programs The Coalition provides technical assistance, training, and public education to local crisis centers and their communities. BOLI/TA protects the rights of workers and citizens to equal, non-discriminatory treatment; encourages and enforces compliance with state laws relating to wages, hours, terms and conditions of employment; and advocates policies that balance the demands of the workplace and employers with the protections of workers and their families. NAO is a technical assistance resource for non-profits. The Foundation Center maintains a comprehensive database on U.S. grantmakers and their grants. The BOLI Civil Rights Division enforces civil rights laws; Investigate civil rights complaints; advises and educates workers about their civil rights This is part of the Oregon Department of Justice website and provides information on crime victim rights and services for both advocates and victims. OATH is the official website of OHTTF. OHTTF was formed to address a growing need for a comprehensive and collaborative response to human trafficking in the State of Oregon. The site provides basic human trafficking information

80 RESOURCE PURPOSE WEB-ADDRESS The National Victim Notification Network Justice Solutions Free Management Library TechSoup: The technology place for nonprofits Asian & Pacific Islander Institute on Domestic Violence National Association of Volunteer Programs in Local Government Futures Without Violence The Battered Women's Justice Project The VINE system keeps victims informed about offenders. Justice Solutions is a national non-profit organization dedicated to enhancing rights, resources and respect for victims and communities. The site is a great resource across topics. The Free Management Library has a wealth of information, resources and references in 75 categories regarding leadership and management. TechSoup provides a range of technology services for nonprofits, including news and articles, discussion forums, and discounted and donated technology products. The Asian & Pacific Islander Institute on Domestic Violence is a national network serving as a forum for, and clearing house on information, research, resources and critical issues about violence against women in Asian and Pacific Islander communities. NAVPLG is an international association of administrators for volunteer programs in local, city, and county government. There is a best practices section, a yahoo group that volunteer managers can join. Futures Without Violence, formerly Family Violence Prevention Fund, works to prevent violence within the home, and in the community, to help those whose lives are devastated by violence. BWJP provides technical assistance and training to a variety of professionals in all areas of law related to domestic violence

81 RESOURCE PURPOSE WEB-ADDRESS National Human Trafficking Resource Center Women s Law ASISTA NHTRC is a national, toll-free hotline where you can connect with anti-trafficking services in your area, request training and technical assistance, general information, or specific antitrafficking resources. Provides easy-to-understand legal information and resources to women living with or escaping domestic violence or sexual assault. Provides technical assistance and training for advocates and attorneys facing complex legal problems in advocating for immigrant survivors of domestic violence and sexual assault

82 APPENDI H VOCA GLOSSARY OF TERMS Accounting Principles: Accrual Accounting Principles: Cash Assistance in Filing Compensation Claims Authorized Official Central Contractor Registry (CCR) Commingling of Funds Conditional Award Criminal Justice Support/Advocacy Crime Victim Crisis Counseling Accrual basis is the method of recording revenues in the period in which they are earned, regardless of when cash is received, and reporting expenses in the period when the charges are incurred, regardless of when payment is made. Cash basis is the method of reporting revenues and expenses when cash is actually received or paid out. Includes making victims aware of the availability of crime victim compensation and assisting the victim in completing the required forms and in gathering the needed documentation. It may also include follow-up contact with the victim compensation agency on behalf of the victim. An Authorized Official is defined as the person(s) within the agency who is legally responsible for obligating the organization to receive funding, to incur indebtedness and to comply with the requirements of the VOCA grant. The Central Contractor Registration (CCR) is a web-enabled government wide application that collects, validates, stores, and disseminates business information about the federal government's trading partners in support of the contract award, grants, and the electronic payment processes. Literally means mixing together and when used in a legal context is a bread of trust in which a fiscal agent mixes funds making it difficult to determine which funds belong to a particular grant or fund. Accounting system of all grantees must ensure that VOCA funds are not commingled with funds from any other source. Funds specifically budgeted and/or received for one grant project may not be used to support another. All grant awards are made conditional upon the timely completion of grant award documents. Funds are not considered obligated and will not be transferred until all required grant award documents have been signed by an applicant and by the Department designee. In addition, an award may be made conditionally if the grantee is not current in reporting for any previous grant award; has fewer than two full years of operational history in providing services to victims of domestic violence and sexual assault; has not fully demonstrated the ability to successfully manage any previous Fund awards. See additional information on page 17 of this Handbook. Refers to law enforcement and prosecution investigation support, assistance during investigation, and explanation of procedures, etc. Included in this definition are: court-related support, i.e., court orientation, court escort, case appearance notification, case status and disposition information, victim impact reports, assistance with restitution, witness fees, intimidation or protection services, transportation, child care, property return, etc.; and post-sentencing services following the disposition of a criminal court proceeding, including offender release notification at the probation, parole, and pardon stages of the criminal justice system, etc. For the purposes of this program, a crime victim is a person who has suffered physical, sexual, financial or emotional harm as a result of the commission of a crime. Refers to in-person crisis intervention, emotional support, and guidance and counseling on an individual basis provided by counselors, mental health professionals or peers. Such counseling may occur: a) at the scene of a crime; b) immediately after a crime; c) at the first, in-person contact between a counselor and victim (this would include meeting a victim in an emergency room, police station, district attorney s office, etc.); d) during in-person contact for the duration of the crisis experience; or e) in the case of survivors of homicide victims of DUI/DWI, counseling may occur months after the victimization.

83 Crisis Hotline Direct Costs DUNS Number Duplicated Services Emergency Financial Assistance Emergency Legal Advocacy Equipment Follow-up Contact Grant Agreement Grant Monitoring: Desk Review Grant Monitoring: Phone Review Grant Monitoring: Site Visit Grant Monitoring: Technical Assistance Group Treatment/Support. Typically refers to the operation of a 24-hour telephone service, 7 days a week, which provides counseling, and information and referral to victims and survivors. Activities that extend and enhance services to victims of crime. These include all of the allowable services as listed on pages 7-12 in this Handbook. The DUNS number is a unique nine-character number that identifies your organization. It is a tool of the federal government to track how federal money is distributed. Obtaining a DUNS number places your organization on Dun & Bradstreet marketing list that is sold to other companies. You can request not to be added to this list during your application. Refers to the method of counting services to victims for statistical purposes. A service is counted each time a client is provided such a service during a given report period. Services to clients will spread across report periods. Refers to locating emergency loans and petty cash; assistance in filing for losses covered by public and private insurance programs including worker s compensation, unemployment benefits, welfare, and Medicare; and payment for taxis, food, emergency shelter, and clothing. Refers to filing temporary restraining orders, injunctions and other protective orders, elder abuse petitions, and child abuse petitions but does not include criminal prosecution or the employment of private attorneys for non-emergency purposes. Tangible nonexpendable personal property having a useful life of more than one year and an acquisition cost of $5, or more per unit. Refers to individual emotional support, empathetic listening, and guidance for other than crisis reactions after the victimization. The legal document between a grantor and a grantee/subgrantee that describes in detail the obligations under the terms of the grant. A grant agreement must be approved and signed by an authorized signatory before a program can receive funds. Review of documentation submitted by a grantee/subgrantee, typically financial and programmatic/statistical documentation over a pre-determined period of time. These documents will be reviewed for accuracy and compliance with terms and conditions of the grant and followed by a conference call using a desk audit review form. This type of monitoring may be used as an alternative to an in-person site visit. A phone review or conference call is a component to both the desk audit and the inperson site visit. A phone review provides the grantee/subgrantee the opportunity to: 1. Prepare for the in-person site visit and 2. To discuss issues as they relate to program activities or documentation in a desk audit. A site visit refers to the monitoring of a grantee/subgrantee by a fund coordinator at the place of business. A site visit is preceded by a phone review to prepare the agency for the in-person visit. Typically financial and programmatic/statistical documentation will be reviewed over the phone and viewed at the site visit. Site visits afford a fund coordinator the opportunity to look closely at the grantee s operation, meet with management and staff and to establish a positive working relationship between the monitoring agency and the service provider. Technical assistance is provided to a grantee/subgrantee at their request. The Fund Coordinator will meet with the grant project director and any grant funded staff. The purpose of this visit is to help ensure the grantee/subgrantee understands the grant requirements and to offer assistance and respond to questions. Refers to the coordination and provision of supportive group activities. This category includes self-help, peer, social support, drop-in groups, and community crisis intervention in a group setting.

84 Indirect Costs Information and Referral (in-person) Information and Referral (telephone). Match (Cash) Match (In-Kind) MOU Outcome Measures Performance Measures Personal Advocacy. Personal Identifying Information RFA Shelter/Safe House Supplanting Target Outputs Indirect costs are costs of an organization that are not readily assignable to the particular grant, but are necessary to the operation of the organization and the performance of the grant (i.e., information services, payroll costs, depreciation and administrative salaries). The costs of property liability insurance on buildings, capital improvements, security guards and body guards, property losses and expenses, real estate purchases, mortgage payment and construction may not be supported with VOCA funds. Refers to in-person contacts with the victim and identifying services offered and support available by the subgrants project and other community agencies Refers to telephone contacts with the victim and identifying services offered and support available by subgrant projects and other community agencies. A program s cash outlay used to support a specific grant. Cash match include nonfederal money contributions from public agencies or private foundations grants and private organizations or individuals. Examples include: Unitary Assessment, United Way funds, ODSVS, DHS Marriage License Tax funds (MLT and CFAA only) A value placed on non-cash contributions used to support the program grant. In-kind contributions include: donations, pro-rated work space, volunteers, office supplies. Memorandum of Understanding. An MOU is required of an agency when they have applied for funds with partnering organizations. The MOU provides documentation that demonstrates the organizations have consulted and coordinated the responsibilities of their grant activities. Changes in participants lives as a result of the staff activities. Markers that indicate whether the program has met its objectives. Performance measures consist of target outputs and short term outcome measures. Refers to assisting victims in securing rights and services from other agencies; intervention with employers, creditors and others on behalf of the victim; and other general information on rights and remedies available to the victim. Individually identifying information for or about an individual victim of crime including (1) a first and last name; (2) a home or other physical address; (3) contact information (including a postal, or Internet protocol address, or telephone or facsimile number); (4) a social security number; and (5) any other information, including date of birth, racial or ethnic background, or religious affiliation, that, in combination with any other non-personally identifying information would serve to identify any individual. Request for Application Refers to offering short-term and long-term housing and related support services to victims and members of their family following victimization Federal funds must be used to supplement existing funds for program activities and NOT replace those already funded. VOCA funds are intended to expand or enhance direct victim services. Therefore, federal grant funds may not be used to supplant, replace or divert other sources of support within government agencies unless it can be demonstrated that such other support is, or will be, eliminated or reduced for reasons other than the receipt of federal VOCA funds. This supplantation clause applies only to state and local public (government) agencies. Nonprofit agencies are not bound by non-supplantation rules. These are proposed results of staff activities. Target outputs should show the: number of clients served, types of client served, length of time that it will take to serve the clients and number and type of services delivered.

85 Therapy Tribal Government Underserved victim Unduplicated victims Unliquidated Obligations Refers to intensive professional psychological/psychiatric treatment for individuals, couples, and family members. This includes the evaluation of mental health needs, as well as the actual delivery of psychotherapy The governing body of an Indian tribe; or a tribe, band, pueblo, nation, or other organized group or community of Indians, including any Alaska Native village or regional village corporation that is recognized as eligible for the special programs and services provided by the United States to Indians because of their status as Indians. An underserved crime victim is a victim of a violent or other traumatic act that is criminal in nature, as defined by state, tribal, military, or federal statute, who does not receive adequate services and support or who lacks understanding of, or access to, statutorily or constitutionally defined legal rights. Underserved victims may be defined as senior citizens, non-english speaking residents, persons with disabilities, or members of racial or ethnic minorities; or they may be defined by their gender, sexual preference, socio-economic status, or religious affiliation; or they may be defined by virtue of the fact that they are residents of rural or remote areas, or inner cities. Victim services may be available in a community, but may not be provided in a culturally competent manner, may not be accessible, or may be complicated by overlapping or complex jurisdictional issues. Refers to the method of counting victims for statistical purposes. Victims are counted only once on a statistical report during a grant cycle (1 or 2 years). The only exception would be if the individual is a victim of another crime. See additional information on pages of this Handbook. Obligations or encumbered funds made toward the end of a grant period for which payment cannot be processed until after the grant period has ended. In most instances, these types of unliquidated obligations will be due to accrued payroll expenses or, on rare occasions, an approved operating expense item, which had been ordered by the end of the grant period but not yet paid.

86 APPENDI I SUBCONTRACTOR INSURANCE REQUIREMENTS A. REQUIRED INSURANCE. Subcontractor shall obtain at subcontractor s expense the insurance specified in this section prior to performing under this Contract and shall maintain it in full force and at its own expense throughout the duration of this Contract and all warranty periods. Subcontractor shall obtain the following insurance from insurance companies or entities that are authorized to transact the business of insurance and issue coverage in the State of Oregon and that are acceptable to Agency (Grantor). i. WORKERS COMPENSATION. All employers, including Subcontractor, that employ subject workers, as defined in ORS , shall comply with ORS and shall provide workers' compensation insurance coverage for those workers, unless they meet the requirement for an exemption under ORS (2). ii. EMPLOYERS' LIABILITY. Required by Agency Not required by Agency. If Subcontractor is a subject employer, as defined in ORS , Subcontractor shall obtain employers' liability insurance coverage. iii. PROFESSIONAL LIABILITY Required by Agency Not required by Agency. If in the conduct and implementation of the Subcontract, Subcontractor provides professional advice or services, Subcontract shall obtain and maintain Professional Liability Insurance covering any damages caused by an error, omission or any negligent acts related to the professional services to be provided under this Contract. iv. COMMERCIAL GENERAL LIABILITY. Required by Agency Not required by Agency. Subcontractor shall obtain and maintain Commercial General Liability Insurance covering bodily injury, death, and property damage in a form and with coverages that are satisfactory to the State. This insurance shall include personal injury liability, products, and completed operations. Coverage shall be written on an occurrence basis. v. AUTOMOBILE LIABILITY INSURANCE: AUTOMOBILE LIABILITY. Required by Agency Not required by Agency. If in the conduct and implementation of the Subcontract, Subcontractor provides transportation for and/or transports individuals in automobiles, Subcontractor shall obtain and maintain Automobile Liability Insurance covering all owned, non-owned, or hired vehicles. This coverage may be written in combination with the Commercial General Liability Insurance (with separate limits for Commercial General Liability and Automobile Liability B. ADDITIONAL INSURED. The Commercial General Liability insurance and Automobile Liability insurance required under this Contract shall include the State of Oregon, its officers, employees and agents as Additional Insureds but only with respect to Subcontractor s activities to be performed under this Contract. Coverage shall be primary and non-contributory with any other insurance and self-insurance.

87 C. TAIL" COVERAGE. If any of the required professional liability insurance is on a "claims made" basis, subcontractor shall either maintain either tail" coverage or continuous "claims made" liability coverage, provided the effective date of the continuous claims made coverage is on or before the effective date of this Contract, for a minimum of 24 months following the later of (i) Subcontractor s completion and Agency s acceptance of all Services required under this Contract, or, (ii) The expiration of all warranty periods provided under this Contract. Notwithstanding the foregoing 24-month requirement, if Subcontractor elects to maintain tail coverage and if the maximum time period tail coverage reasonably available in the marketplace is less than the 24- month period described above, then Subcontractor shall maintain tail coverage for the maximum time period that tail coverage is reasonably available in the marketplace for the coverage required under this Contract. Subcontractor shall provide to Grantee or Agency, upon Grantee or Agency s request, certification of the coverage required under this Exhibit E. D. CERTIFICATE(S) OF INSURANCE. Subcontractor shall provide to Grantee Certificate(s) of Insurance for all required insurance before delivering any Goods and performing any Services required under this Contract. The Certificate(s) must specify all entities and individuals who are endorsed on the policy as Additional Insured (or Loss Payees). Subcontractor shall pay for all deductibles, self-insured retention and self-insurance, if any. The Subcontractor shall immediately notify the Grantee of any material change in insurance coverage.